In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, theContinue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties
U.S. Supreme Court Rules Against Government in FBAR Penalty Case
The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy act applies on a “per-form” basis, not a “per-account” basis, handing individuals an important victory.
Continue Reading U.S. Supreme Court Rules Against Government in FBAR Penalty Case
IRS Cracks Down on Charitable Contributions of Cryptocurrency
By Adam R. Young and Brian Bernhardt
On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM…Continue Reading IRS Cracks Down on Charitable Contributions of Cryptocurrency
Georgia Residents Eligible for $3,000 Tax Exemption for Each ‘Unborn’ Child
Beginning with the 2022 tax year, Georgia residents may claim a $3,000 tax exemption on their Georgia state income tax return for each qualifying “unborn” child.
On August 1, 2022…Continue Reading Georgia Residents Eligible for $3,000 Tax Exemption for Each ‘Unborn’ Child