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
Memorandum to Defer Employment Taxes Until 12/31/2020
On August 8, President Trump issued a Memorandum deferring payroll tax obligations due to COVID-19. It directs the IRS to defer the withholding, deposit, and payment of the 6.2 percent employee’s share of Social Security taxes, between September 1 through the end of this year. Additionally, the IRS… Read More