Penalties

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.

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.

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.

Newsletter Articles

TAX REFORM

Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.

DEDUCTIONS

Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.