Given its limited resources and ability to detect foreign assets, accounts and income, the IRS has offered various voluntary programs to entice taxpayers to come clean and report this information. The IRS’s OVDP program and the more recent streamlined procedures are two examples. The Maze v. Internal Revenue Service, Nos. 15-1806 (D.D.C. 2016), highlights several… Continue reading The IRS’s Streamlined Procedures for Foreign Accounts
Category: Tax Procedure
Online Payment Account Triggered FBAR Filing, Poker Websites Did Not
In Hom v. United States, No. 14-16214 (9th Cir. 2016), the court addressed whether an online payment account and whether poker websites triggered FBAR filing requirements. FBAR Filing Requirements Taxpayers with an interest in or authority over certain…
Online Account Trigger FBAR Filing, Not Poker Websites
In Hom v. United States, No. 14-16214 (9th Cir. 2016), the court addressed whether an online payment account and whether poker websites triggered FBAR filing requirements. The stakes are high with FBAR penalties, so those with foreign accounts should take heed. FBAR Filing Requirements Taxpayers with an interest in or authority over certain foreign accounts… Continue reading Online Account Trigger FBAR Filing, Not Poker Websites
Court Says Five IRS Audits in Ten Years is Not Harassment
In Appenrodt v. United States, No. 3:16-cv-02010-LB (N.D. Cal. 2016), the court concluded that the IRS did not harass a taxpayer by subjecting the taxpayer to five audits in ten years. The facts and procedural history of the case are as follows: The IRS audited Mr. Appenrodt’s individual income tax returns for tax years 2005-2008.[…]
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Five IRS Audits in Ten Years is Not Harassment
There are times when the IRS does not act reasonably. It happens. There are also instances where a few IRS employees take it upon themselves to thoroughly examine all aspects of the taxpayer’s finances. Taxpayers do have rights, but these rights only go so far. This brings us to the Appenrodt v. United States, No.… Continue reading Five IRS Audits in Ten Years is Not Harassment
IRS Whistleblower Claimants May Be Entitled to Larger Awards
The IRS is often gets more from whistleblowers than one may think. Specifically, the IRS may be able to recoup taxes, penalties and interest for other years or related but different issues. There is a question as to whether the whistleblowers who shine the light on these other years or issues should be compensated for… Continue reading IRS Whistleblower Claimants May Be Entitled to Larger Awards
Taxpayer Not Entitled to Attorneys Fees Despite Prevailing In Lawsuit
The government makes mistakes. It is not perfect. The United States v. Appelbaum, No. 5:12-CV-186 (W.D.N.C. 2016) , case provides an example. In Appelbaum, the government sued the taxpayer for nearly $4 million that the taxpayer did not owe. The question before the court was whether the taxpayer could recover attorneys fees he incurred in… Continue reading Taxpayer Not Entitled to Attorneys Fees Despite Prevailing In Lawsuit
Failing Business Triggers Trust Fund Penalties
Taxes are often neglected when a business is having financial difficulties. This can have serious repercussions for the business and the individuals who are responsible for having taxes withheld and remitted to the IRS. The IRS has the ability to assess trust fund recovery penalties against these individuals, which essentially makes the business tax liability… Continue reading Failing Business Triggers Trust Fund Penalties
Choosing Not to Comply With an IRS Summons
The law requires taxpayers to keep certain records. The IRS expects taxpayers to produce these records on request. The IRS has the power to issue an administrative summons if the taxpayer does not cooperate. This begs the question as to what happens if…
Choosing Not to Comply With an IRS Summons
The law requires taxpayers to keep certain records. The IRS expects taxpayers to produce these records on request. The IRS has the power to issue an administrative summons if the taxpayer does not cooperate. This begs the question as to what happens if the taxpayer chooses not to comply with an IRS summons? The United… Continue reading Choosing Not to Comply With an IRS Summons