IRS penalties
Proof of Cash on Hand to Abate Failure to Pay Penalty
The failure to pay penalty is one of the most commonly assessed penalties. The penalty does not apply and can be abated or removed if the taxpayer can establish that the failure to pay is due to reasonable cause and not to willful neglect. In C1 Design Group, LLC v. United States, 1:15-cv-146-CWD (D. Ohio […]
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Facts Needed to Abate Penalties Based on Reasonable Cause
Taxpayers often contest penalties by arguing that their failures were due to reasonable cause. Many of these penalty abatement requests are resolved at the administrative level. The cases that end up being litigated typically do not have the best facts…
IRS Collections for U.S. Military Personnel
Judicial and administrative proceedings are temporarily suspended for those serving in the United States military. This includes a temporary hold on IRS collection actions. These laws are not provided in the Tax Code. Rather, they are set out in the Se…
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…
Court Affirms that Tax Prepearer Fraud Holds Open Assessment Statute
In Finnegan v. Commissioner, T.C. Memo. 2016-118, the U.S. Tax Court refused to reconsider its previous decision that a tax return preparers fraud keeps the statute of limitations open on the taxpayer’s Federal income tax return. The facts and procedural history are as follows: On February 7, 2013, the IRS issued a notice of deficiency […]
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