A recent case from the 11th circuit, U.S. v. Henco Holding Corp., is an important case in regard to the tax enforcement of transferee liability. The two biggest takeaways from the case are: one, a reminder that a state statute of limitations is not binding on the IRS,… Read More
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IRS Statutory Notice of Deficiency and Last Known Address
The IRS Statutory Notice of Deficiency is perhaps the most important Tax Notice a taxpayer can receive. It prescribes strict timelines to challenge proposed IRS actions and is a taxpayer’s ticket to Tax Court. If a taxpayer misses the prescribed 90-day deadline to file a Tax Court petition,… Read More
IRC 6676 Excessive Refund Claim Penalty
I thought this blog post would be helpful because it involves a little-known IRS penalty section, IRC 6676. IRC 6676 imposes a 20% penalty to the extent that a claim for refund or credit with respect to income tax is made for an “excessive amount.” An “excessive amount”… Read More
Deferred Payroll Tax Repayment Extended
IRS Notice 2021-11 explains how employers who deferred payroll taxes on behalf of their employees can withhold and pay the deferred taxes throughout 2021 instead of just by, or no later than, April 30, 2021. Payments made by Jan. 3, 2022, will be considered to be timely because… Read More
Joe Biden’s “American Rescue Plan”
President Biden’s $1.9T COVID-19 relief package comes on the eve of this presidency and is designed to aid the economy and react to poor market news (jobless claims) and to contain the pandemic. Some of the key provisions include: an additional round of stimulus checks, $2,000 direct payments… Read More
FBAR Penalties: Per Account, Per FBAR
Just last year, a taxpayer in the Fifth Circuit won a case against the IRS challenging its assertion of non-willful FBAR penalties on a per account basis. Now, there is more of the same in 2021. In Kaufman, DC Conn. Jan. 19, 2021, the Court ruled that the… Read More