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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About: Ronald Marini
Recent Posts by Ronald Marini
IRS Review of Foreign Reporting Information Results in Another 50% FBAR Penalty Case
A real estate developer willfully failed to report an overseas bank account to the Internal Revenue Service and is responsible for $456,000 in penalties, a Texas federal court found on June 11,2019. Defendant Edward Flume is a U.S. citizen who has lived and worked in Mexico since 1990. A savvy businessman, Flume has successfully parlayed…
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Few Accuracy-Related Penalties Are Proposed in LB&i Examinations and They Are Generally Not Sustained on Appeal!
The Internal Revenue Service tends to impose relatively few accuracy-related penalties during audits of large businesses, according to a new report. The report, from the Treasury Inspector General for Tax Administration, noted accuracy-related penalties are generally 20 percent of the underpayment of taxes due, and in certain cases, the penalty can be as high as…
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Senate Passes IRS Reform Bill
The Senate passed the Taxpayer First Act (H.R. 3151) on Thursday, June 13 by a voice vote. The bill includes provisions to improve customer service, protect personal data, preserve tax-preparation services and curb private debt collectors. The measure now goes to the President who is expected to sign. On June 6, House Ways and Means Committee…
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