Our tax law imposes penalties on taxpayers who fail to file tax returns or pay taxes on time, unless the taxpayer can show “reasonable cause” for the delay. In United States v. Boyle, the Supreme Court established a bright-line rule that reliance on an accountant or agent does not constitute “reasonable cause.” There are nuances……
Tag: IRS Penalties
The Evolution of Foreign Account Tax Reporting
The IRS and Treasury face a number of challenges in administering our tax and financial systems. This includes challenges presented by foreign transactions by U.S. citizens and residents. In recent years, high-profile cases involving Americans using offshore accounts to evade taxes have prompted the U.S. government to crack down on tax evasion and make it……
When a Fictitious Business is Reported on Your Tax Return
So you reported a fictitious business on your income tax return. The fictitious business resulted in a tax loss and, maybe, you got a large tax refund from the IRS as a result of it. It’s a fraudulent tax return. The IRS sends you an IRS audit notice. What do you do? The answer varies,……
Court: Complex Tax + Professional Advice = No Tax Penalty
We know that we can take steps to minimize our taxes. Our tax laws allow for this and, on review, the courts have made this clear. Tax penalties are usually the problem with taking tax positions in situations that are not entirely clear. Taxpayers who find themselves having to make decisions in these gray areas……
The Injunction for Tax Return Preparers
The government often has a myriad of remedies available to it. There are common situations in which the government does not have a consistent and thoughtful process for organizing how and when it will pursue the various remedies. This ad hoc method often results in outcomes that are not tailored to achieve the government’s aims……
Bookkeeper Liable for Trust Fund Recovery Penalty
IRS employees are tasked with making decisions. These decisions dictate who owes taxes and penalties and who does not. These decisions are usually made in the context of well trodden areas and by employees who make the same type of decisions over and over. This is due to the volume of disputes that are created……
IRS Says Congress’ Penalty Relief Not Available
To be viable, businesses have to pay for their operations and, after-tax, produce a profit or return. The tax burden can make it very difficult to produce a profit. This is particularly true when sales taxes and payroll taxes are considered. The sales tax is imposed on the transfer of property (and in some states……