Taxpayer -These are applied to each tax year with no statue of limitation Filing Requirement Form IRC Penalty section U.S. person with interest in: Foreign Corporation (FC) Form 5471 IRC 6038(b) Foreign Partnership (FP) Form 8865 FC or FP with Foreign Disregarded Entity Form 8858 Penalty reducing Foreign Tax Credit: Foreign Corporation (FC) Form 5471…
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Where's My Multimillion-Dollar Refund?
An Overview of the IRS Joint Committee Review Process By SusanStanley and Janice Flood In the current economic environment, many corporate taxpayers are faced with losses that when carried back will result in an overpayment of tax in excess of $2 million; any refund in excess of $2 million, whether claimed on IRS Form…
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Whistleblower Case Hinges on IRS Time Frame for Setting Awards | BNA Software
Whistleblower Case Hinges on IRS Time Frame for Setting Awards | BNA Software Read more at: Tax Times blog
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Willfulness in trust fund penalty must be determined at trial
In a summary judgement, a district court has concluded that a taxpayer who was vice-president, board member, and shareholder of his family-run company was a responsible person for purposes of the Code Sec. 6672 trust fund recovery penalty. However, the district court found that whether the taxpayer, who played a perfunctory role in his company,…
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