For a further exploration of penalty defenses, including 6751(b), please see our firm video: Here are the facts of another taxpayer win under IRC 6751(b): A married couple’s civil fraud penalty was not timely approved by an IRS Revenue Agent’s (RA’s) supervisor as required under Code Sec. 6751(b)(1)…. Read More

Currently before the Supreme Court is the question of whether certain tax provisions of the Affordable Care Act are constitutional. If they are not constitutional, it could result in refunds being due to taxpayers who paid additional Medicare taxes and those high earners who paid the Net Investment… Read More

The IRS recently clarified that crypto investors who only “purchased” digital assets using fiat but did not sell or transact those assets during 2020, do not need to report their purchases on page 1 of their 1040s. The IRS cryptocurrency FAQs were updated on the IRS website, stating:… Read More

It is without question that 2020 was a bang-bang year for crypto investors. Many generated a substantial amount of short-term capital gains. And with the IRS making clear that cryptocurrencies are “property” for tax purposes, not true currency, this put the spotlight on the taxability of crypto transfers… Read More

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

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