On May 16, 2019 we posted E Filing Errors as Reasonable Cause? Not For Now! where we discussed a recent US Court of Appeals for the Fifth Circuit decision, Haynes v. United States, No. 17-50816 (5th Cir. Jan. 29, 2019), indicates that many of those taxpayers will face uncertainty if their returns are late due to preparer…
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TIGTA Report Show Amended Tax Returns Still Prone to Fraudulent Refunds
The Internal Revenue Service hasn’t done enough to improve its procedures for reviewing amended tax returns to reduce erroneous and fraudulent tax refunds, according to a new report. The report, from the Treasury Inspector General for Tax Administration, followed up on earlier reports by TIGTA that found risks of fraudulent and erroneous tax refunds from…
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No Statute of Limitations Defense Where Fraud is Involved!
The Tax Court found in Kohan, TC Memo 2019-85 that a dentist's underreporting of income was due to fraud. Therefore, there was no period of limitations to assess the taxes he owed. IRC Sec. 6501(a) generally requires the IRS to assess a tax within three years after the filing of a return. However, when a taxpayer has filed…
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Tax Treaties Face Additional Obstacles After 10 Years of Delay
On July 31, 2019 we posted Senate OKs Tax Treaties With Spain, Japan, Switzerland & Luxembourg, where we discussed that Senate approved on July 17, 2019 three bilateral tax treaties with Switzerland, Luxembourg and Japan, one day after approving a treaty with Spain.The treaties were approved after years of inaction on the agreements, a development welcomed by…
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