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Yearly Archives: 2012

Res judicata prevented a taxpayer's innocent spouse claim

The Tax Court has held that the doctrine of res judicata prevented a taxpayer from relitigating a claim for innocent spouse relief. It also held that the taxpayer did not meet the conditions for overcoming res judicata under Code Sec. 6015(g)(2). (Eugene Koprowski, (2012) 138 TC No. 5) Background. Each spouse is jointly and severally…
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Administration's Proposed New Tax on Family Trusts.

Each 90 years, trusts will pay the new 45 percent estate tax.  The tax is on the value of its assets.   Trust funded before this law is passed are exempt. You need to move fast. The Administration hasissued a 200-page report with new tax laws including this law. While many new loopholes and tax breaks are…
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Treasury, IRS Issue Proposed Regulations for FATCA Implementation

WASHINGTON — The Treasury Department and the Internal Revenue Service today issued proposed regulations for the next major phase of implementing the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, the law targets non-compliance by U.S. taxpayers using foreign accounts. The regulations lay out a step-by-step process for U.S. account identification, information…
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