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Yearly Archives: 2018

Supreme Court Agrees That Recklessness = Willful Failure To File FBAR!

On December 20, 2016 we posted Recklessness = Willful Failure ToFile FBAR For Partial Disclosure in OVDP Filings? where we discussed that a district court had found that the taxpayers' failure to timely file a Foreign Bank and Financial Accounts Report (FBAR) was willful where, among other things, they stopped employing a bookkeeper or keeping any books after opening…
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Nail Salon Supplier Get Nailed For Filing A False Tax Return

According to the DoJ a resident of Troy, Michigan, pleaded guilty on April 26, 2018 to filing a false tax return. According to court documents, Mythi Nguyen co-owned Y & B Nail Supply, a nail salon wholesale business located in Madison Heights, Michigan.      From 2009 through 2011, Nguyen underreported more than $1.1 million in…
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1st Taxpayer Victory in a “Willful” FBAR Penalty Case Appealed!

On March 7, 2018 we posted 1st Taxpayer Victory in a "Willful" FBAR Penalty Case! where we discussed that on September 20, 2017, the Eastern District of Pennsylvania issued an important taxpayer friendly opinion regarding the "willfulness" standard in FBAR penalty matters.  In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the…
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IRS' $173 Million IRS Tech Team Failed on Tax Day?

According to Forbes, not even 1,500 highly compensated tech employees at the IRS could keep the website running on Tax Day, the most important day of the year for taxpayers and the IRS. Although tax season is busy throughout March and April, it all comes down to one day. This year, on April 17, when…
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