The following tale is the first in a two part series relating to a couple of recent decisions from the United States Tax Court. Both decisions center around the often-litigated topic of a taxpayer’s profit-motive and whether those taxpayers should have been the allowed the losses stemming from their breeding businesses. On December 21, 2021, [...]
In January of 2018, the Internal Revenue Service (IRS) issued a press release advising delinquent taxpayers to negotiate reasonable alternatives to enforced collection action, or risk losing their passport. Please find more on that press release and the IRS’s initial approach to passport revocation here. Suffice to say, the initial process for passport revocation was [...]
The on-going COVID-19 pandemic has had a dramatic impact on the daily operations for the Internal Revenue Service (IRS). The IRS has appeared to have done its level best to provide taxpayers with options for securing vital documentation. Though, taxpayers attempting to obtain a lien release or certificate of discharge have experienced some delays in [...]
On March 25, 2020, the Internal Revenue Service (IRS) announced its “People First Initiative,” a program intended to respond to the challenges of Covid-19 by providing a variety of relief related to IRS deadlines and collection actions. For additional information, please see our previous blog article regarding the People First Initiative here and the full [...]
People often joke that the only certainties in life are death and taxes. Well, it turns out that, when it comes to the report of Foreign Bank and Financial Account (FBAR) penalties, death may have finally met its match. The Southern District of Florida issued a decision in United States v. Green, 2020 BL 165965 [...]
This is the sixth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]
This is the fifth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]
This is the fourth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]