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 [...]
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 [...]
The U.S. Supreme Court recently refused to hear an appeal from the Ninth Circuit Court of Appeals in Knappe v. United States of America, 713 F.3d 1164 (9th Cir., 2013), cert denied, 134 S. Ct. 422 (2013). The issue was whether an estate could rely on the advice of a CPA as to when a [...]