Affirming the Tax Court’s decision, the Eleventh Circuit Court of Appeals has ruled that the fraud exception to the 3-year statute of limitations on assessments applied where a married couple’s returns were fraudulently prepared by their preparer. (Finnegan, (CA 11 6/11/2019)) As many of us do, John and Joan Finnegan ("Taxpayers") hired someone to prepare their tax…
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Negligent FBAR NOT Limited to $10K Per Year
How Can The IRS Impose 13 Negligent FBAR Penalties For 1 Year? Ask the federal district court of California, which recently upheld the IRS’ imposition of separate non-willful penalties against 13 foreign accounts disclosed on a single late FBAR return. The court’s decision raises the stakes for taxpayers looking to quietly report their foreign interests…
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IRS Summons For Law Firm's Client Identities Can Be Enforced
According to Law360, the U.S. can enforce an Internal Revenue Service summons for client information from the Taylor Lohmeyer Law Firm because the firm failed to show attorney-client privilege protected the information, a Texas federal court found. The court, in a order, approved a John Doe summons the government sought to obtain the names of…
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Foreign Sub's Guarantee of US Loan Results in Additional Income
According to Law360, the Third Circuit on May 14, 2019 upheld decades-old tax regulations tied to a $377 million dispute involving the affiliate of a commodities trader, ruling that the IRS wasn’t expected to foresee every possible impact of the rules when they were written. In a precedential ruling, a three-judge panel affirmed a U.S.…
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