Tag: penalties

25
Mar

Federal Income Tax Return Filing and Payment Relief

Last week, the Treasury Department and the Internal Revenue Service (IRS) announced that the filing deadline for certain returns has been extended from April 15, 2020 to July 15, 2020 (Notice 2020-18) and they also provided some payment relief in response to the COVID-19 national emergency.  Although this is an ever-evolving and fluid situation, for the time being the Treasury

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18
Mar

Optional 90 Day Extension on IRS Payments

The Trump Administration announced its new economic stimulus plan today which includes an option for taxpayers to delay their tax payments for 90 days.  The plan allows deferrals of up to $1 million for individuals and up to $10 million for corporations on their tax payments for up to 90 days.  Taxpayers are still encouraged to file their tax returns

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11
Feb

Recent Tax Court rulings may allow refunds of previously assessed penalties

By: Derek B. Wheeler, Esq. and Heather L. Marello, Esq. As part of the Restructuring and Reform Act of 1998 (“RRA 98”), Congress enacted IRC §6751(b)(1), which requires written supervisory approval for certain penalties proposed by the IRS.  Much of RRA 98 focused on legislative controls to prevent abusive practices by IRS personnel which had come to light in the

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13
Jun

IRS Completes Unprecedented Campaign Targeting Employment Tax Crimes

By: Kevin Murphy, Esq. In our most recent blog post, we discussed the importance of timely payment of payroll taxes and how serious the IRS is taking the issue of criminalizing the Trust Fund Recovery Penalty. As a follow up, we wanted to pass along a recent news release from the IRS that highlights the conclusion of an unprecedented two

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31
May

WHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 2)-CRIMINAL EXPOSURE

By: Kevin Murphy, Esq. In Part 1, of this blog, we explained and discussed the civil aspects of IRC 6672- the Trust Fund Recovery Penalty (TFRP). At the end of Part 1, we mentioned that the civil statute is virtually identical to the criminal statute. The two statutes are highlighted below: Section – IRC 6672 (Civil) Any person required to collect,

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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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