The Court of Appeals for the Sixth Circuit has reversed a district court's Summary Judgment decision that a company's President and CEO/Chairman were liable for the Code Sec. 6672 penalty, finding that there were legitimate factual disputes regarding whether they acted recklessly in failing to pay the trust fund taxes. Notably, although the two were…
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Changes in Criteria for Taxpayer Advocate Service acceptance of Cases
The Taxpayer Advocate Service (TAS) changed its criteria for accepting individual taxpayer cases for assistance, reducing the instances in which it will accept cases. The TAS said it took this action so that it can focus on cases “where we can add the most value.” In a notice to taxpayers and tax professionals, the TAS…
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IRS’s Voluntary Disclosure Data-Mining Program
Attorney Jay Nanavati published “Why Holders of Foreign Bank Accounts Need to Worry About IRS's Voluntary Disclosure Data-Mining Program” in Bloomberg BNA's Daily Tax Report. In this Article Navavati asks "Have you ever been surprised by Facebook or LinkedIn’s ability to suggest people to whom you may be connected, when even you had forgotten how you…
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IRS Issuing Erroneous Letters to Taxpayers on Form for Foreign Trusts
The American Institute of CPAs (AICPA) has become aware of a widespread problem affecting numerous taxpayers across the country (including taxpayers in: California, Florida, Maryland, Massachusetts, New York, and Washington) as well as taxpayers in Canada who are receiving incorrect letters from the Internal Revenue Service (IRS) regarding the completion and filing of Form…
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