Tag: IRS

10
Sep

WHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 1)

By: Kevin Murphy, Esq. PART ONE When we discuss potential liability for the Trust Fund Recovery Penalty (TFRP)- I.R.C. § 6672, we often find the need to explain how payroll taxes work.  Many clients, some lawyers and accountants and unfortunately even some IRS agents and Assistant U. S. Attorneys don’t really understand what constitutes a trust fund liability.  Everyone has

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23
May

Planning to file a Delinquent 1120F Return? Make sure you know the Risks.

By: Lou Carlow On February 1, 2018 the Commissioner of Internal Revenue, Large Business and International Division (LB&I) issued a memorandum providing guidelines for handling delinquent Forms 1120-F and requests for waivers pursuant to Treas. Reg 1.882-4(a)(3)(ii), that states “No one involved in a compliance function should accept as filed a delinquent Form 1120-F from a taxpayer or discuss in

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8
May

TAKE NOTICE!

By: Royston Mendonza, Esq. The IRS has a repository of hundreds of notices that it issues to Taxpayers for a variety of issues. In fact, a statement of IRS notice codes released in 2002 is 120 pages long.  Many of these notices, if left unaddressed, carry little to no associated consequences.  However, there are certain notices which serve as warnings. 

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11
Apr

Are 2018 State and Local Real Property Taxes Paid in 2017 deductible or not? The Answer’s in the Statute.

By: John L. Marien On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act.  In light of the various tax cuts contained in the revisions to the Internal Revenue Code, Congress was compelled to formulate legislation that would recover some of the lost revenue.  One provision aimed at recovering a portion of this revenue loss

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27
Mar

Recent Tax Court Ruling Limits Statute of Limitations for Foreign Account Reporting

By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his tax return.  Taxpayers use Form 8938 to report to IRS foreign bank accounts and other specified foreign financial

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19
Mar

IRS Offshore Voluntary Disclosure Program Will End on September 28, 2018

By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency urged taxpayers who still have not come forward to do so before the program ends. The 2014 OVDP is the last evolution of the program IRS

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22
Feb

Can you discharge your tax debt through Bankruptcy?

By: Gary P. Bluestein, Esq. The general view of most accountants and attorneys we talk to is that tax debt is not dischargeable in Bankruptcy. When we tell them that a tax debt may indeed be dischargeable, people are typically very surprised. While there are many factors that determine whether a tax debt is dischargeable in a bankruptcy filing (primarily

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31
Jan

Andreozzi Bluestein Litigators Achieve Precedential Tax Court Victory for United States Virgin Islands Taxpayers

In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of Deficiency against them as time barred. Andreozzi Bluestein LLP represented the Petitioners in this case before the Tax Court. The Petitioners claimed

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23
Jan

FBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness

By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,

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