A responsible person may be subject to the TFRP if it can be shown he or she willfully failed to pay the trust fund taxes due.
A taxpayer was not entitled to challenge a penalty, which was already disputed in an administrative proceeding at the IRS Appeals office, in a CDP hearing.
Treasury and the IRS continue their scrutiny of captive insurance transactions that they deem to be abusive.
This item explores the risks for certain delinquent or substantially incomplete international information returns.
The IRS issued a notice that provides guidance on the de minimis safe harbor from information reporting penalties and the payee election not to have the safe harbor apply.
This item discusses the two penalty areas that apply to preparers.
This item summarizes some common IRS penalties and the procedural and practical ways practitioners can obtain a penalty abatement.
To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income tax return.
A pattern of fraudulent conduct in a tax accountant’s preparation of his clients’ returns was not sufficient to prove that underpayments on his own returns were due to fraud.
The IRS issued final rules for the penalty imposed on material advisers for failing to provide the IRS a list of advisees with respect to reportable transactions.
This item outlines the pros and cons of the various types of installment agreements.
Congress passed the Trade Facilitation and Trade Enforcement Act of 2015, making permanent the moratorium on states and localities taxing Internet access.
The IRS issued final rules on how to apply the $10,000-per-day penalty under Sec. 6708 when a material adviser fails to provide the Service a list of advisees with respect to reportable transactions.
Qualifying taxpayers who failed to report foreign-source income and can prove their conduct was not "willful" could enjoy significantly reduced penalties.
This item discusses the PATH legislation’s immediate impact on certain federal penalty computations.
The Tax Court held that a notice of determination from a collection due process hearing is valid for purposes of starting the period in which a taxpayer must file a petition with the Tax Court if the notice is actually received by the taxpayer.
IRS could impose penalty because the examiner had made an initial determination that the penalty applied.
Passports can be denied to any person whom the IRS certifies as having seriously delinquent tax debt.
A recently enacted law requires penalties for failing to file certain information returns to be adjusted for inflation. The latest adjustments are announced in this guidance.
The guidance provides procedures to ensure consistency and efficiency in the IRS’s administration of the FBAR compliance program.