According to Law360, The U.S. Senate passed an expansive tax cut bill early Saturday that is projected to add more than $1 trillion to the deficit, after garnering enough support from faltering and fiscally conservative Republicans. The Tax Cuts and Jobs Act, or H.R. 1, passed by a vote of 51-49, with Sen. Bob Corker, R-Tenn.,…
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Will Marinello Be The McDonnell Of Tax Crimes?
According to Law360, Carlo Marinello will argue to the U.S. Supreme Court next month that a vague tax law gives prosecutors power to criminalize anything that makes the IRS' job harder, in a case that could see the high court continue limiting broad criminal laws as it did last year in U.S. v. McDonnell. Marinello was…
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Partner-Level CDP Case Can Be Revied by the Tax Court
The Tax Court in McNeill, 148 TC No. 23 (2017), held that it has jurisdiction under Section 6330(d)(1) to review a notice of determination when the underlying tax liability consists of a penalty relating to an adjustment to a partnership item excluded from deficiency procedures by Section 6230(a)(2)(A)(i). The taxpayer was a partner in a…
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Online Poker Accounts Not Subject to FBAR But Payment Processing Account Is.
In U.S. v. Hom, (CA 9 7/26/2016), 118 AFTR 2d ¶ 2016-5057 the Court of Appeals for the Ninth Circuit, affirming in part and reversing in part a district court decision, has found that one of three accounts a taxpayer maintained to facilitate online poker was with a financial company and had to be reported on…
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