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Monthly Archives: June 2019

Few Accuracy-Related Penalties Are Proposed In LB&I Examinations snd They Are Generally Not Sustained On Appeal

According to TIGTA'S Final Report issued on May 31, 2019, few accuracy-related penalties are proposed in LB&I examinations and they are generally not sustained on appeal. Highlights of Reference Number:  2019-30-036 to the Commissioner of Internal Revenue.    IMPACT ON TAXPAYERS Taxpayers who underreport their income tax may be subject to accuracy-related penalties (Internal Revenue Code Section…
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US Taxpayers Living or Working Outside the U.S. Must File a Return by June 17th

The Internal Revenue Service issued IR-2019-102 on June 5, 2019 and reminded taxpayers living and working outside of the United States that they must file their 2018 federal income tax return by Monday, June 17, 209 The June 17 deadline applies to both U.S. citizens and resident aliens abroad, including those with dual citizenship. An extension of…
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Correspondence Sent by IRS Were Not Notices of Disallowance

In Hale v. United States, 2019 U.S. Claims LEXIS 502 (May 14, 2019), the Court of Federal Claims has held that various items of correspondence from IRS to a taxpayer were not notices of disallowance and, thus, did not start the two-year period for initiating a refund lawsuit. IRC § 6532 establishes jurisdictional time limitations…
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