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Illinois Tax Delinquency Amnesty Act: What You Need to Know

Falling behind on taxes can feel overwhelming, but Illinois is offering taxpayers a second chance. The Illinois Tax Delinquency Amnesty Act of 2025 creates a limited-time opportunity for individuals and businesses to pay off overdue state taxes without having to shoulder the added burden of penalties and interest. By giving taxpayers with outstanding obligations a [...]

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IRS Heeds Taxpayer Advocate’s Advice on Foreign Gift Tax Penalties

On October 24, 2024, Commissioner Daniel Werfel announced that the Internal Revenue Service (IRS) would end its practice of automatically assessing penalties for late-filed forms relating to foreign gifts or bequests, effective immediately. Contrary to popular belief, such penalties were frequently assessed against lower-income taxpayers, immigrants, and small businesses. The change in procedure, which relates [...]

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Employee Retention Credit Voluntary Disclosure Program Ends March 22, 2024

The Employee Retention Credit (ERC) is a refundable tax credit for certain eligible business and tax-exempt organizations that had employees and were affected during the COVID-19 pandemic. The ERC Voluntary Disclosure Program is meant to help employers pay back the money they received after incorrectly filing for ERC claims. Businesses who incorrectly claimed the ERC [...]

Calendar with 31st circled in blue, pennies stacked and a calculator.

When Winning Isn’t “Prevailing”: Success in Bankruptcy Court Does Not Translate to Attorneys’ Fees

In June 2016, William Canada, Jr. took the Internal Revenue Service (IRS) to bankruptcy court and won. Mr. Canada successfully challenged the IRS’s claim for a $40 million penalty, pursuant to IRC §6707, for failing to report tax shelter transactions under IRC §6111. Per IRC §6707, the IRS imposes a penalty on anyone who fails [...]

Senior couple thinking about financials.

IRS Acted “Against Equity or Good Conscience” to Deny Hardship Due to Depression

On April 20, 2017, the United States Tax Court (Court) held in favor the petitioners, John C. Trimmer and Susan Trimmer (together, the Trimmers) against the Commissioner of Internal Revenue, regarding the Internal Revenue Service’s (IRS’s) authority to consider a hardship waiver and the notion that the IRS’s authority on the hardship waiver is not [...]

How to Appeal the Trust Fund Recovery Penalty After the Appeal Period has Passed: Offer in Compromise, Doubt as to Liability

There are many reasons businesses fall behind on paying their federal tax liabilities. Falling behind on certain kinds of taxes, sometimes called “trust fund” taxes, may result in the IRS assessing those taxes against the business owners, officers, or other individuals the IRS considers to be “responsible” for ensuring the payment of those taxes.  Federal [...]

State Sales Tax and Corporate Income and Franchise Tax After Wayfair

On June 21, 2018, The United States Supreme Court ruled 5-4 in South Dakota v. Wayfair that states can mandate that businesses without a physical presence in a state but with more than 200 transactions in or $100,000 in in-state sales must collect and remit sales taxes on transactions in the state. In this article, [...]

IRS Taxpayer Roadmap

The Internal Revenue Service (IRS) Taxpayer Advocate Service (TAS) recently released the above “subway map” to illustrate, at a very high level, the stages of a taxpayer’s journey through the tax system. The map provides a high level overview of the processes for tax return preparation, tax return processing, notices from the IRS, audits, appeals, [...]

IRS Announces Increase to Late Filing Penalties for 2018 Federal Tax Returns

The IRS recently announced that taxpayers who owe tax and did not file their 2018 returns before Friday, June 14, 2019 will be subject to increased late filing penalties.  penalty kicks in. The failure-to-file penalty is assessed if there is unpaid tax and the taxpayer fails to file a tax return or request an extension [...]

Taking Advantage Of Expanded Penalty Relief

The recent enactment of the Tax Cut and Jobs Act (TCJA) put many individual taxpayers in a difficult position regarding their estimated tax obligations for the 2018 tax year. Fortunately, the Internal Revenue Service (IRS) released Information Release and Notice (IR) 2019-55 expanding the guidance for penalty relief relating to the underpayment of individual income [...]

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