The widow of a personal injury lawyer is responsible for $2.7 million in liabilities for the years 1996 through 2001, as the couple filed joint income tax returns but did not pay the balance of their tax liabilities when filing the returns, the U.S. Court of Appeals for the Fifth Circuit held July 24 (United…
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Reporting of PFIC Assets Not Required on Both Forms 8621 and 8938
Taxpayers who report their passive foreign investment company assets on the Form 8621 do not have to separately detail them as specified foreign financial assets on the Form 8938, an Internal Revenue Service official said July 24. The development comes as taxpayers are focusing on the requirement to report those specified assets under new tax…
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Tax Court Petition Was A “Proceeding” That Extended Limitations Period On Assessment
In SHOCKLEY v. COMM., the Court of Appeals for the Eleventh Circuit, reversed the Tax Court, and held that a Tax Court petition filed by former shareholder-officers of a corporation qualified as a “proceeding in respect of” the corporation's multimillion dollar deficiency that suspended the statute of limitations under Code Sec. 6503(a)(1). Accordingly, the notices…
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4th DCA Reverses DC – Intent to Evade Taxes Does Not Makes sequent Violations of FBAR Rules Willful – Willful Blindness Does.
United States v. J.Bryan Williams; No. 10-2230 Decided: July 20, 2012 Reversed by unpublished opinion. Judge Shedd wrote the majority opinion, in which Judge Motzconcurred. Judge Agee wrote a dissenting opinion. Unpublished opinions are not binding precedent in this circuit. The parties agree that Williams violated § 5314 by failing to timely file an FBAR for…
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