March 7, 2018 we posted 1st Taxpayer Victory in a "Willful" FBAR Penalty Case! where we discussed that on September 20, 2017, the Eastern District of Pennsylvania issued an important taxpayer friendly opinion regarding the "willfulness" standard in FBAR penalty matters and In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the court…
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All That You Wanted to Know About Form 706NA – Part II
We previously posted All That You Wanted to Know About Form 706NA - Part I, where we discussed that in the area of estate tax compliance, many of us have prepared Form 706’s, the estate tax return for US citizens and domiciliaries. To be sure, this form is quite voluminous and can take a while…
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Taxpayer Appeals Ct of Claims Ruling Upholding FBAR Penalty in excess of $100,000
The Court of Federal Claims, granted summary judgment in IRS' favor earlier this year, determining that a taxpayer's failure to file a Report of Foreign Bank and Foreign Accounts (FBAR or FinCEN Form 114 was willful and upheld IRS's imposition of a $697, 229 penalty, i.e., an amount greater than the $100,000 maximum set out in regs…
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Painter Who White Washes Tax Liability Pleads Guilty to Tax Evasion
According to DoJ, a Long Island, New York, business owner pleaded guilty today to tax evasion. According to documents filed with the court, Warren J. Krotz, 62, of Huntington, New York, owned and operated W. Krotz Enterprises Inc. (WKEI), a professional painting business that provided services throughout Long Island. Krotz admitted to evading both his…
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