IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
Continue Reading IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
Tax Controversy Litigation
FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split
Introduction
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines…
Continue Reading FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit SplitThe IRS has started its own Employee Retention Credit Olympics
Coinciding with the opening day of the Olympic games, the IRS issued IR-2024-198, again stating that it will deny tens of thousands of ERC claims that, according to the…
Continue Reading The IRS has started its own Employee Retention Credit OlympicsShould You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?
As Employee Retention Tax Credit (ERC) claims pile up and the IRS shows no signs of lifting its moratorium on processing claims filed after September 14, 2023, businesses with unpaid…
Continue Reading Should You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?IRS and Congress Expand Efforts to Address ERC Fraud
There are several new developments in the Internal Revenue Service’s ongoing campaign to combat false and fraudulent Employee Retention Credit (ERC) claims.
They include an indefinite extension of the agency’s…
Continue Reading IRS and Congress Expand Efforts to Address ERC FraudIRS Going All in on Use of ArtificiaI Intelligence
The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news…
Continue Reading IRS Going All in on Use of ArtificiaI IntelligenceTax Court Rules IRS Cannot Assess Certain International Reporting Penalties
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, the…
Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting PenaltiesIncrease in IRS Funding Leading to More Audits of Public Charities
As part of the Inflation Reduction Act, the IRS will receive a nearly $80 billion funding increase, including more than $45 billion for enforcement, over the next decade. Audit staff…
Continue Reading Increase in IRS Funding Leading to More Audits of Public CharitiesU.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
U.S. Tax Court to Begin Accepting Hand Deliveries on July 10
Following up our post earlier today that the Tax Court will resume receiving mail on July 10, 2020, the Tax Court has issued another announcement regarding its operations. Also beginning…
Continue Reading U.S. Tax Court to Begin Accepting Hand Deliveries on July 10