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Counsel’s admission costly to taxpayer in FBAR case

The Third Circuit affirmed a district court’s holding that a taxpayer’s failure to report his foreign accounts on FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (FBAR), was willful.

AICPA asks IRS to expand penalty relief

The AICPA, in a letter to the IRS, urged the Service to expand the relief under Notice 2022-36 to include several other Code sections and forms and to extend the deadline for requesting relief to Dec. 31, 2022.

Offer in compromise not deemed accepted

An offer in compromise submitted during a Collection Due Process proceeding is not deemed accepted under Sec. 7122(f) if it is returned to the taxpayer within 24 months of submission.

Microcaptive insurance arrangements after CIC Services

A federal district court recently held that Notice 2016-66, which classifies certain microcaptive insurance arrangements as transactions of interest that are reportable transactions under Regs. Sec. 1.6011-4, is invalid under the Administrative Procedure Act. This article discusses the ramifications of the decision for taxpayers engaging in microcaptive insurance transactions and possible responses to the decision by the IRS.

IRS relieves penalties for 2019 and 2020

As part of COVID-19 pandemic relief, the IRS will automatically abate failure-to-file penalties for certain tax and information returns and refund those penalties already paid.