Yesterday, the Tax Court issued a 63 page opinion finding that the taxpayers were not entitled to a $499,000 charitable contribution deduction for the donation of an apartment building to Volunteers for America because the taxpayers failed to obtain a qualified...
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Post-Return Conduct Can Be Insufficient for Finding of Civil Fraud Penalty
On December 3, 2014, the United States Tax Court issued an opinion in Brown v. Commissioner, T.C. Memo. 2013-275, in which the Court found that the taxpayers were not liable for the fraud penalty under Internal Revenue Code (I.R.C.) section 6663(a) despite the fact...
IRS Launches “Get Transcript” Online Service to View, Print, and Download Tax Transcripts
Yesterday the White House issued a statement on The White House Blog regarding its Education "Datapalooza," an event intended to further the exploration of new apps and services advancing higher education. The White House blog post references a fact sheet describing...
National Taxpayer Advocate Releases 2013 Annual Report Urging the Adoption of a Taxpayer Bill of Rights
Today the National Taxpayer Advocate issued a press release to report the publication of the 2013 Annual Report to Congress. IR-2014-3. The press release emphasizes a few key items from the report: a recommendation that the IRS adopt a "Taxpayer Bill of Rights," and...
Husband not liable for tax where IRA distributions were made pursuant to forged withdrawal requests
In a case of first impression, the Tax Court held that a taxpayer did not fail to report income attributable to unauthorized IRA distributions where his former wife had likely forged the withdrawal requests and where he received no economic benefit from the...
‘Like kind’ property exchanges subject to new California bill
When using a Section 1031 exchange under the Internal Revenue Code, property owners can defer recognition of gain for "like kind" property exchanges. Under the IRS rules, tax on this property may not be due until the time that investors actually sell the...
Foreign Financial Institutions can now get more information regarding FATCA Resources and Support
The FATCA FFI List Resources and Support Information Webpage has been posted to the FATCA Website. In addition, the FATCA FFI List Frequently Asked Questions (FAQs) have been posted to the FATCA Website.
Fourth Circuit finds Fifth Amendment privilege inapplicable to documents required to be maintained under the Bank Secrecy Act
Last Friday, the Fourth Circuit Court of Appeals affirmed a district court's refusal to quash subpoenas related to foreign bank account records that were required to be maintained under the Bank Secrecy Act and Treasury Regulations.The case involves an investigation...
IRS updates FATCA Registration System
This FATCA Registration Update Summary provides a summary of the updates made to the FATCA Registration System located on the FATCA Website. An updated version of the FATCA Registration Online User Guide (PDF) is available.For more information, click here.
Arizona laundromat owner found liable for fraud penalties for unreported check-cashing income
Yesterday the Tax Court issued an opinion in Abdallah v. Commissioner, T.C. Memo. 2013-279, finding that a laundromat owner had fraudulently underreported income for several years and was liable for civil fraud penalties under I.R.C. § 6663(a). In addition to...
