According to Law360, a U.S. Senate Finance Committee member on January 22, 2019 questioned the legality of the Internal Revenue Service plan to recall 46,000 furloughed workers next week, which the agency would execute if the partial federal government shutdown remains in effect. Sen. Mark Warner, D-Va., the ranking member of the committee’s taxation and IRS…
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The IRS Computer is Continuing to Generate Notices of Levy During This Government Shutdown
For your information, the IRS computer is continuing to generate Notices of Levy, during this IR/Government shutdown. It's been my experience that just about every IRS fax number is not functioning, during this government shutdown and you will receive a busy signal when these IRS fax numbers are dialed. So trying to contact anyone at…
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IRS Clarifies “Willfulness” Under FBAR Rules
In Program Manager Technical Advice 2018-013, the IRS has set out the definition of "willfulness," and the standard of proof for establishing willfulness, for purposes of the penalty for willful violation of the requirements of the Report of Foreign Bank and Financial Accounts (FBAR). Under 31 USC 5314(a) and 31 C.F.R. 1010.350, every U.S. person that has…
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Another Anti-Taxpayer FBAR “Willfulness” Decision
On January 7, 2019 we posted 1st Taxpayer Victory in a "Willful" FBAR Penalty Case Overturned at Appeals where we discussed that on May 1, 2018 we posted 1st Taxpayer Victory in a "Willful" FBAR Penalty Case Appealed! and now a recent 2nd Circuit Court of Appeals opinion weighed in on two uncertainties regarding willfulness in context…
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