The Internal Revenue Service on May 20, 2019 released the 2018 IRS Data Book, a snapshot of agency activities for the fiscal year. The 2018 IRS Data Book describes activities conducted by the IRS from Oct. 1, 2017, to Sept. 30, 2018, and includes information about tax returns, refunds, examinations and appeals. The annual publication…
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Tax Preparer's Fraudulent Intent Was Sufficient To Keep Limitations Period Open For the Taxpayer
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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