Tag: IRS

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

Read more

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,

Read more