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.
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TOPICS
IRS Practice & Procedure
Newly released IRS Data Book numbers confirm decline in audit rates
A number of factors have led to a decline in IRS examinations over the past few years, and a dearth of IRS examiners could cause that trend to continue.
How to submit third-party authorization forms online (and use ID.me)
The IRS strives to expand online service offerings while balancing convenience with the need to keep taxpayer data safe from hackers.
AICPA again critiques new IRS requirements for R&D credits
In a second letter, the AICPA takes issue with broad new documentation requirements for refund claims involving the Sec. 41 credit, outlined in an IRS memo in fall 2021.
Penalty relief deadline fast approaches for 2019, 2020 tax returns
Taxpayers must file by Sept. 30 to qualify for late-filing penalty relief from the IRS.
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.
No relief for trust fund recovery penalty
A TFRP liability is not eligible for Sec. 6015 innocent-spouse relief because it is not a liability related to a joint return.
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 service issues highlighted in national taxpayer advocate report
The annual midyear report for fiscal 2023 reviewed the IRS’s performance in the 2022 tax filing season and outlined 14 “systemic advocacy objectives” going forward.
AICPA disputes ‘misleading’ claims on new IRS funding, calls for service improvements
Despite “confusion and misinformation” about the Inflation Reduction Act’s allocations, concerns continue about the funding levels for taxpayer service, the AICPA’s president and CEO said.
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.
National taxpayer advocate appeals IRS response on scanning tech
National Taxpayer Advocate Erin Collins escalated her push for the IRS to adopt barcode scanning of paper tax returns, but the IRS would commit only to a goal of scanning certain 2022 returns.
Meaning of ‘filed’ defined for purposes of delinquent partnership returns
Delinquent partnership returns are ‘filed’ when they are delivered by the requested method to and received by an IRS official authorized to receive such returns;
IRS may enforce lien to pay off deceased life partner’s tax debts
Property of a taxpayer may be used to satisfy the tax liabilities of a life partner.
Cryptoasset clarity needed for private fund managers
This item outlines the risks private fund managers should consider when investing their portfolio in cryptoassets.
Some balance-due notices on joint returns issued in error, IRS says
Payments made by the second-listed spouse on a joint return for 2021 under certain conditions may not have been properly credited by the IRS.
IRS seeks transformation in new 5-year plan
The IRS’s fiscal 2022–26 Strategic Plan sets out goals to modernize its operations and interactions with taxpayers while adapting to new challenges and threats.
Pandemic-paused IRS return preparer visits could resume by video
The U.S. GOA recommended that the IRS pilot videoconferencing for its program singling out “high-risk” return preparers for direct compliance checks and education with respect to refundable tax credits and other taxpayer tax benefits.
AICPA recommends additional IRS backlog measures
Looking ahead to next filing season, the AICPA renews previous calls for taxpayer relief and administrative remedies to help the IRS clear overages in its return and correspondence inventories.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
