In September, the IRS announced a government procurement contract seeking contractors to provide protocols and software tools to trace privacy coins transactions. The proposal calls for “expert tools, data, source code, algorithms, and software development services” to assist IRS Cybercrime Agents in identifying wallets, transaction dates, times and… Read More
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6751(b) Defense of IRS Penalties
If you’ve ever had an IRS penalty assessed against you, you know how distressing that can be. Here, I discuss Internal Revenue Code (IRC) section 6751(b), Procedural Requirements of IRS Penalties. It is a Code section that defines the legal requirements the IRS must follow “before” assessing a… Read More
IRS Now Allows Electronic Signature on a Total of 16 Tax Forms
Due to COVID-19, the IRS now allows 16 different tax forms to bear electronic signatures. The tax forms are those that must be paper-filed and that cannot otherwise be electronically filed. The IRS seeks to reduce in-person contact and taxpayer and tax practitioner exposure to COVID-19. Below is… Read More
New IRS Notice and Disallowance of PPP Funded Business Expenses
According to IRS Notice 2020-32, business expenses that are normally deductible in computing taxable business income may not be deductible if the taxpayer uses funds from a forgiven PPP loan to pay such expenses. In its Notice, the IRS “disallows any otherwise allowable deduction under any provision of… Read More
Foreign Bank Account Reporting (FBAR) Options
When a U.S. person has unreported foreign accounts, they may need an FBAR Attorney to represent them. But a little background on the options available may help him or her make better decisions on how to proceed. What constitutes a “foreign account” and what triggers a reporting requirement… Read More
IRS Response to the Taxpayer First Act: Case Designation for Litigation
The Taxpayer First Act mandated that the IRS expand and strengthen taxpayer rights and reform itself into a more taxpayer friendly agency by requiring it to develop a more comprehensive customer service strategy, modernize its technology and enhance its cyber security. Through it – just to name a… Read More