The Internal Revenue Code requires employers to withhold certain taxes in “a special fund in trust for the United States” (sec. 7501(a)). IRS regulations require employers to pay these trust
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The Hazards of Trust Fund Recovery Penalties
The recent Tax Court decision in Woodley v. Commissioner, T.C. Memo. 2017-242, demonstrates the hazards of trust fund recovery penalties (TFRPs) for taxpayers. A TFRP is a penalty imposed…
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Pennsylvania Supreme Court: Corporate Tax Refund Claim Must Be Filed Within Three Years Of Original Tax Return Due Date
In Mission Funding Alpha, the Pennsylvania Supreme Court recently held that the statute of limitations for a corporation to file a refund claim in Pennsylvania begins to run when…
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Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
The issue before the Tax Court in Huzella v. Commissioner, T.C. Memo. 2017-210, centered around a coin business on eBay, and whether the petitioner, Thomas Huzella, could substantiate his…
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Tax Court Denies Treaty Benefit to Canadian Post–Doctoral Fellow
In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation…
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Tax Court Broadens Foreign Earned Income Exclusion
The Tax Court’s recent decision in Linde v. Commissioner, T.C. Memo. 2017-180, brought good news to taxpayers working outside the United States. In Linde, the Tax Court held…
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