The IRS abused its discretion in failing to consider the taxpayers’ proposed offer in compromise, installment agreement request, and economic hardship claim.
By knowing the factors courts consider in determining whether a taxpayer meets the requirements for the reasonable-cause exception, and how the courts have applied the factors, tax advisers can help their clients properly mount a defense to an accuracy-related penalty.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
This item discusses some key U.S. tax implications and unanswered questions of cryptocurrencies and identifies possible avenues of relief for taxpayers with unreported income or assets connected to cryptocurrency.
The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings.
The failure to update the regulations to reflect a statutory increase in the FBAR penalty amount prevents the IRS from assessing the full statutory amount of the penalty.
The Sec. 6676 penalty is equal to 20% of the amount by which the claim for refund or credit exceeds the amount allowable for the tax year at issue.
An automated process for first-time abatements could ensure consistent application of relief for taxpayers.
Practitioners can protect themselves from significant penalties by following the IRS’s ‘adequate disclosure’ procedures.
A taxpayer must be aware of a pending tax-related proceeding to be convicted of obstructing or impeding due administration of the Code.
The IRS is ending the Offshore Voluntary Disclosure Program just as its enforcement of cryptocurrency compliance increases.
The IRS stated it would challenge the tax benefits of certain syndicated conservation easement transactions.
Taxpayers can use various techniques to minimize estimated tax payments throughout the year while also avoiding underpayment penalties.
This article focuses on the potential criminal consequences that can arise when a business fails to collect or pay over withheld tax.
Tax Court held that the IRS was not authorized to add underpayment interest or additions to tax to the restitution taxpayers were ordered to pay as part of a sentence for criminal tax violations.
The Tax Court found that a taxpayer had reasonably relied on her preparer’s advice in determining which year to include income.
Relying on a tax professional does not guarantee that the penalty will be removed for a taxpayer.
Practitioners should have a basic awareness of some of the unique tools the government uses to enforce employment tax laws.
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.