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...
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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...
2014 Standard Mileage Rates for Business, Medical and Moving Announced
The Internal Revenue Service today issued the 2014 optional standard mileage rates used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes.Beginning on Jan. 1, 2014, the standard mileage rates for the use...
California Offers Tax Relief on Short Sales
On Wednesday, December 4, the Franchise Tax Board followed the IRS's lead in announcing that it will not impose a tax penalty on taxpayers who sell their home for less than is owed, commonly referred to as a "short sale". The determination means California taxpayers...
Supreme Court Upholds Valuation Misstatement Penalty for Disallowed Partnership Losses
Yesterday the Supreme Court held that the 40% gross valuation misstatement penalty under I.R.C. § 6662(h) is applicable in cases where the IRS determines that a partnership is a sham or lacks economic substance. United States v. Woods, No. 12-562 (U.S. Dec. 3,...
Reminders for Year-End Charitable Donations
In addition to achieving philanthropic goals, many people make charitable donations at the end of the year in order to maximize income tax benefits. To make sure your charitable donation accomplishes both charitable and tax-savings benefits, here are few...
Tax Court finds former IRS agent liable for fraud penalty due to guilty plea in prior criminal proceeding
Yesterday the Tax Court issued an opinion in Senyszyn v. Commissioner, T.C. Memo. 2013-274, finding in favor of the IRS on summary judgment that a former revenue agent was liable for a fraud penalty and that the statute of limitations on assessment remained open....
Tax Court Rejects IRS Interpretation of Accuracy-Related Penalty Calculation
Earlier this week the U.S. Tax Court issued a court-reviewed opinion finding that the IRS has been improperly calculating accuracy-related penalties in certain cases involving refundable credits (i.e., the earned income credit, the additional child tax credit, and the...
IRS Advisory Council Recommends Changes which Benefit Taxpayers and Practitioners
In its 2013 annual report, the IRS Advisory Council has made several recommendations which would be favorable to taxpayers. The Council recommends an expansion of voluntary correction programs for taxpayers who self-report problems from prior years as well as changes...
