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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....
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...
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...
One IRS official has indicated that the focus of tax audits concerning small businesses may shift from corporations to varying types of partnerships. This is in part because partnerships have grown in number and have also become more complex.The concern regarding...
The Internal Revenue Service has announced the nationwide rollout of a streamlined settlement program for small businesses and individuals under examination by the Small Business/ Self-Employed Division of the IRS. Previously, this program was available as a pilot...
The U.S. Department of the Treasury has announced that the United States has signed an intergovernmental agreement (IGA) with France to implement the Foreign Account Tax Compliance Act (FATCA). Enacted in 2010, FATCA aims to curtail offshore tax evasion by...
Congress is considering closing the wind energy production credit at the end of this year. This could affect a number of property owners and businesses that have set up wind turbines in California if the credit ends. There is the possibility of benefits...
There appears to be controversy concerning the manner that professional athletes are taxed in the state of California. The average NFL player earns $2 million. California's personal income tax rate is now at 13.3 percent - the highest in the United States. For...
On October 31, 2013, the IRS issued Rev. Proc. 2013-35 in which it announced that the Unified Credit Against Estate Tax for decedents dying in 2014 is $5,340,000 per person. This is a $90,000 increase for inflation. The IRS also confirmed that the annual gift tax...
The United States Department of Treasury has issued a news release today regarding the FATCA FFI Agreement. Click here to access the FFI Agreement that foreign financial institutions must use.If you have any questions, call our office at our office.
