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
Crypto Tax Software Partners with Coinbase
One of the largest U.S.-based cryptocurrency exchanges, Coinbase, partners with Cointracker to provide tax reporting forms to its Coinbase users. The automatically generated tax forms, reporting gains and losses, will include IRS Form 8949, Schedule D and Schedule 1. This is akin to the year-end statements investors typically… Read More
Timeliness of CDP Appeals Hearing Requests
An important change to taxpayer’s IRS Collection Due Process (CDP) Appeals rights is coming soon to the IRS Internal Revenue Manual (IRM). Because of the importance of filing Form 12153, Request for IRS Appeals consideration, to the “correct” address and the confusion that can be caused by IRS… Read More