Supreme Court – Third-Party Collection Summons – Notice | May 25, 2023
Supreme Court refuses to hear Toth case thereby permitting the 50% penalty for willful failure to file FBAR to stand | January 30, 2023
FBAR Due Date | April 15, 2022
Identity Theft – Internal Revenue Service | April 11, 2022
Internal Revenue Service chimes in on Worker Classification: Employee or Contractor | December 28, 2021
Innocent Spouses Must Actually Be Innocent | September 20, 2021
An Executor may be personally liable for unpaid Estate Taxes | August 2, 2021
A Corporation Can Be Held Liable For Payroll Taxes On Wages It Should Have Paid Its Owners / Officers | July 19, 2021
New decision by United States Tax Court discusses expanded rights for testifying for innocent spouse relief | May 18, 2021
Estate Planning after the 2020 election results | January 28, 2021
Husband Can’t Sign Joint Return For Allegedly Insane Wife | February 15, 2017
“Willful” Fail to File FBAR Defined in a California District Court Case | December 16, 2016
Imposition of Attorney’s Fees Unavailable For Undue Influence Absent a Fiduciary Duty | November 30, 2016
Stolen Income is Still Taxable Income | October 24, 2016
Offshore Account Holders Cannot Sue to Enter into More Lax Disclosure Program | October 17, 2016
“Blame The Lawyer” No Excuse To Avoid Penalties For Late Estate Tax Filing | September 27, 2016
Recent Tax Court Decision Finds Against the Abuse Defense in an Innocent Spouse Case | August 8, 2016
No Loss Deduction Available For Retaining Wall Collapse | July 22, 2016
No Clothing Deduction For Wearing Ralph Lauren Clothing | May 10, 2016
Whistleblowers Do Not Get Paid For FBAR Civil Penalties | May 9, 2016
Tax Court Determines Emotional Distress Damages Taxable Since Not Derived from Physical Injury | February 22, 2016
Law Firm Operating as a C Corporation Hit With Non-Deductible Salaries and Dividend Treatment and Penalties When Zeroing Out Income to its Shareholders as Salary Bonus | February 12, 2016
New Innocent Spouse Proposed Regulations Issued | January 8, 2016
Estate Litigation – Father Held Not to Have Abandoned Son and Therefore Entitled to a Share of His Deceased Son’s Estate | December 14, 2015
IRS Explains Deductibility of Business Donations to Entities Where Percentage of Sales Promotion are Donated | October 30, 2015
Autism Spectrum Disorder No Excuse For Late Filing and Payment Penalty Abatement | October 26, 2015
IRS Determines Year Taxpayer Had Theft Loss From Ponzi Scheme | August 7, 2015
District Court Affirms FBAR Penalties but Disallows FBAR Late Payment Penalty and Interest | August 4, 2015
Third Circuit Holds That the IRS Can Compel Production of Foreign Bank Records Over a Fifth Amendment Assertion | July 22, 2015
Innocent Spouse Taxpayer Recovers Litigation Costs by Making a “Qualified Offer” and Then Prevailing in Court | July 20, 2015
Victim of a “Pump and Dump” Scheme Not Entitled to Theft Loss Deduction for Losses Incurred | June 25, 2015
Estate Tax Closing Letters Issued Only Upon Request | June 18, 2015
Lawsuit Settlement Payments Not Deductible For Income Tax Purposes After Claiming Same as a Deduction For Estate Tax Purposes | June 15, 2015
U.S. Flight Attendants Living Abroad Owe Tax When Flying Over the U.S. or International Airspace | June 12, 2015
House Ways and Means Committee Votes to Repeal the Estate and GST Taxes | April 1, 2015
Final Regs Issued on $1 million pay limit | March 31, 2015
Even Minority Shareholders Can Be Hit With Transferee Liability for Unpaid Taxes When the Corporation Does Not Pay the Taxes | March 26, 2015
Tax Court Rules For Bartender On His Tip Reporting Method Over IRS’s Reconstruction Method | March 19, 2015
Another Estate Tax Repeal Bill Is Proposed | March 16, 2015
Bankruptcy Debtor’s Income Tax Liabilities Held Not Dischargeable | November 14, 2014
U.S. Tax Court Upholds $10,000 Penalty Against a Private Foundation Who Filed a Return Late | November 13, 2014
Structuring | November 10, 2014
A Merger of Two Family-Owned Companies May Result in Taxable Gifts| October 8, 2014
Internal Revenue Service is Committed to Whistleblower Program | August 25, 2014
There is no Bankruptcy Protection from Inherited IRAs | July 7, 2014
NEW OFFSHORE VOLUNTARY DISCLOSURE PROGRAM (OVDP) RULES GO INTO EFFECT | June 19, 2014
Commissioner of the Internal Revenue Service Talks of Amending the Offshore Voluntary Disclosure Program (“OVDP”) | June 5, 2014
Israel and U.S. Reach Substantive Agreement | May 1, 2014
When Brothers Feud, They Can Split Up Their Corporation in Two and Go Their Separate Ways in a Tax Free Exchange | April 17, 2014
FBAR Reporting | April 16, 2014
Tax Court Rules on an IRA Prohibited Transactions Case | April 8, 2014
U.S. and Canada Sign Tax Avoidance Agreement | February 6, 2014
Per the U.S. Supreme Court, Every Citizen has Every Right to Save Taxes Legally | December 23, 2013
Swiss Banks Likely to Cave and Disclose U.S. Accounts to U.S. Authorities | December 11, 2013
Internal Revenue Service extends deadline for abused innocent spouses to apply for relief from 2 years to 10 years | December 9, 2013
Federal District Court in Wisconsin Rules Parsonage Allowance to Clergy is Unconstitutional | November 27, 2013
Internal Revenue Service To Get Tougher | November 25, 2013
Per IRS: Married Same Sex Couples Are Married But Unwed Same Sex Couples Are Not | November 18, 2013
Recent Tax Court Case Outlines Factors in Determining Whether the Commissioner’s Determination of a Fraud Penalty Should Be Upheld Against Taxpayer’s Omitting Income | November 5, 2013
Negotiations on a Tax Information Exchange Agreement Between the U.S. and the Cayman Islands Conclude| August 20, 2013
Appellate Court Affirms the Tax Court That the Period to Petition the Tax Court for Denial of a Collection Due Process Hearing is 30 Days | July 29, 2013
John Hom Gets Caught “All In” by Tax Court | July 12, 2013
Supreme Court Hears Two Days of Oral Arguments on the Constitutionality of DOMA in an Estate Tax Case | March 29, 2013
Fiscal Cliff Fallout- The New Investment Income Tax | January 7, 2013
Tax Court Rules Payments to Settle Possible Beneficiary’s Claims Against Estate are not Deductible for Estate Tax Purposes | December 17, 2012
Expiring (Sunsetting) Estate and Gift Tax Laws | November 13, 2012
Sole Shareholder Can Receive Employment Agreement Payment on Sale of Business Rather Than Corporation Because Shareholder Sold His Good Will | November 12, 2012
Sometimes Even With Bad Partnership Documents, Estate Tax Discounting May Be Possible | October 8, 2012
Executors Themselves Can Be Personally Liable for IRS Penalties | August 20, 2012
First Circuit Court of Appeals Finds No Abuse of Discretion in the I.R.S’s Rejection of O.I.C. | July 6, 2012
Tax Court States that Timely Proper Receipts for Charitable Contributions from a Charity are Required for a Donation to be Deductible | June 1, 2012
Clock is Ticking on Estate Planning in 2012 | February 27, 2012
IRA Charitable Rollover Expired on Dec. 31, 2011 | January 9, 2012
IRS Has Invited Practitioners to Comment on the Tax Treatment of Decanting | January 4, 2012
The New Estate and Gift Exclusion Amounts Have Just Been Released for 2012 | October 6, 2011
Obama Sets Forth His Deficit Reduction Plan, Which Includes Estate and Gift Tax Changes | October 3, 2011
New IRS Notice Eliminates Taxation of Personal Use of Employer Provided Cell Phones | September 23, 2011
Tax Advantages of Purchasing Property (including Qualified Real Property) for Business Use This Year | September 16, 2011
The 10 Year Statute of Limitation for Collection After Assessment May Be Extended By an Offer in Compromise | August 22, 2011
Defined Value Gifts Approved by Ninth Circuit | August 17, 2011
Senate Bill Proposes to Eliminate Short Term GRATs | August 15, 2011
Tax Court Sets Value of a Publishing Company Lower than Initially Reported on Estate Tax Return! | July 15, 2011
Tax Court holds that the IRS May Reject a Taxpayer’s Offer in Compromise Where He Dissipates Assets Through Day Trading Losses | April 29, 2011
Obama Administration States Tax Holiday for Corporations that Repatriate Income from Tax Haven Countries is Poor Policy | Sunday, April 03, 2011
President Obama Releases Budget Proposals for 2012, Including Permanent Estate and Gift Tax Reforms | Tuesday, March 01, 2011
Bipartisan Bill Introduced to Repeal the Expanded Form 1099 Reporting Requirement | Thursday, January 27, 2011
Tax Planning Under the New Act | Friday, January 21, 2011
S Corp Built-In-Gain Period Temporarily Shortened | Monday, January 17, 2011
The Hiring Incentives to Restore Employment Act Adds Credit for Hiring New Workers | Monday, January 17, 2011
