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Navigating the Waters of FBAR Compliance: Understanding Penalties under 31 USC 5321, February 1, 2024

Important Update: IRS Notice 2024-7 – COVID-19 Penalty Relief for Taxpayers, December 21

Reporting Requirements of FinCEN for Beneficial Ownership Information (“BOI”), November 1, 2023

Understanding the Difference Between Inventory and Accounting of an Estate, October 3, 2023

New NJ Small Business Lease Grant for First Floor Rentals with 5-Year Lease, September 15, 2023

The Intersection of Politics and Estate Planning: Navigating the Sunsetting of 2016 Estate Tax Cuts, August 25, 2023

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

Recent Tax Court Case Highlights Importance of Tax Counsel in Bankruptcy as Tax Court Finds the IRS Could Pursue Tax Deficiency Even After Bankruptcy Court Approved Taxpayer’s Payment Plan | August 19, 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


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

Pending Legal Malpractice Claim Against a Decedent is Disallowed as a Deduction Under the Federal Estate Tax If Claim Amount is Uncertain | June 6, 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

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