Penalties

Former Partner Liable for Trust Fund Penalty

A taxpayer who asserted he was no longer a partner in a business during the periods at issue was nevertheless held to be a responsible person and liable for the 100% penalty for failure to pay over withheld employment taxes.

Taxpayer Did Not Have Fraudulent Intent

The Tax Court held that a taxpayer who used an “agent-principal” scheme to avoid paying taxes on income from his business was not liable for a civil fraud penalty because the IRS had failed to prove that the taxpayer had fraudulent intent.

Taxpayer Did Not Have Fraudulent Intent

The Tax Court held that a taxpayer who used an “agent-principal” scheme to avoid paying taxes on income from his business was not liable for a civil fraud penalty because the IRS had failed to prove that the taxpayer had fraudulent intent.

IRS Tightens Penalty Relief

Recent IRS actions suggest a movement away from granting penalty relief. Recent budget cuts, furloughs, and negative press have exacerbated the trend by significantly decreasing IRS resources, resulting in slower responses to taxpayer inquiries.

Newsletter Articles

SPONSORED REPORT

How the Election May Affect Taxation of Business Income

This report summarizes recent proposals to reform the U.S. business income tax system and considers the path to enactment of any such legislation.

PRACTICE MANAGEMENT

CPAs Contend With Tax ID Theft

Tax-related identity theft fraud remains a widespread problem that is often difficult for victims and their tax preparers to correct.