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California Tax Law Blog

California Court Holds Reasonable Cause for Penalty Abatement due to the Advice of a Professional only Qualifies when Ambiguity Exists for the Taxpayer

The Ninth Circuit Court of Appeals held that erroneous advice from an accountant that an estate tax return (IRS Form 706) could be extended for filing and payment purposes by one year did not qualify for penalty abatement as "reasonable cause."In Knappe v. United...

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Federal Court in San Francisco Authorizes Service of John Doe Summons on Wells Fargo Seeking the Identities of U.S. Taxpayers with Offshore Accounts

A federal court in San Francisco authorized the Internal Revenue Service (IRS) to serve a John Doe Summons seeking information about U.S. taxpayers who hold correspondent accounts at Wells Fargo for Canadian Imperial Bank of Commerce's FirstCaribbean International...

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