Pesky IRS Penalties: How to Get Them Abated for Clients
This item summarizes some common IRS penalties and the procedural and practical ways practitioners can obtain a penalty abatement.
Penalties
Foreign Information Returns, Income Tax Returns, and Civil Penalties
To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income tax return.
Understatement of Income Not Fraudulent
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.
Material Adviser Penalty Rules Are Clarified
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.
Navigating the Murky Waters of IRS Payment Agreements
This item outlines the pros and cons of the various types of installment agreements.
Legislation Permanently Bans Internet Taxes, Increases Failure-to-File Penalty
Congress passed the Trade Facilitation and Trade Enforcement Act of 2015, making permanent the moratorium on states and localities taxing Internet access.
Final Regulations Clarify $10,000-Per-Day Material Adviser Penalty
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.
Streamlined Filing Procedures for Disclosing Foreign Assets and Income
Qualifying taxpayers who failed to report foreign-source income and can prove their conduct was not "willful" could enjoy significantly reduced penalties.
PATH Brings Changes to Federal Penalty Computations
This item discusses the PATH legislation’s immediate impact on certain federal penalty computations.
CDP Notice of Determination Valid If Actually Received
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 Made “Initial Determination”
IRS could impose penalty because the examiner had made an initial determination that the penalty applied.
Passport Revocation and Third-Party Debt Collection Provisions Enacted
Passports can be denied to any person whom the IRS certifies as having seriously delinquent tax debt.
Guidance Contains Inflation Adjustments for 2015 Information Return Penalties
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.
IRS Provides Guidance on FBAR Penalties
The guidance provides procedures to ensure consistency and efficiency in the IRS’s administration of the FBAR compliance program.
Tax Court: Thou Shalt Not Promote False Tax Shelters
The Tax Court upheld the IRS’s imposition of penalties against a couple for marketing and promoting tax shelters based on the use of a corporation sole.
CPAs May Be Responsible for Clients’ Payroll Tax Penalties
The Erwin case is an important reminder that an accountant can be held liable for a client’s unpaid employment taxes.
Money Can’t Buy Love, but It Can Keep You Out of Prison
Seventh Circuit upheld a district court’s decision to spare Beanie Babies billionaire prison time for evading taxes by hiding assets in a Swiss bank account.
IRS Proposes Rule Updates and Clarifications to Penalty for Nondisclosure of Reportable Transactions
The IRS issued proposed regulations that would update and clarify the rules regarding the penalty for failure to disclose reportable transaction information.
Construction Contractor Hammered on Trust Fund Penalty
The Tax Court held that a responsible person taxpayer was not entitled to currently not collectible status for her liability attributable to a trust fund recovery penalty and that adequate protection payments made to the IRS by her wholly owned corporation could not be applied to her liability.
The Threat of Parallel Investigations: When Civil Isn’t Civil
This article examines recent developments in parallel civil and criminal investigations as they have been reinvented over the past decade.
