The Internal Revenue Code provides the IRS with authority to waive the 60-day IRA rollover requirement “where the failure to waive such requirement would be against equity or good conscience, including casualty, …
In Lamprecht v Commissioner, TC Memo 2022-91 (link to case), a John Doe summons tolled the statute of limitations and allowed the IRS to assess a 20% accuracy related penalty more than …
On Tuesday October 26, 2021, Judge Bloom for the District Court of the Northern District of Florida adopted a Magistrate’s recommendation to issue an order to compel repatriation of funds to satisfy …
On August 16, 2021, the IRS Director of Collection Policy issued a memorandum to provide guidance when FATCA[1] information should be used in IRS Collections cases. See SBSE-05-0821-0015 (the “Memo”) (available at …
Overview A recent federal magistrate’s recommendation highlights a practical battle between the U.S. Government and a Defendant that is seeking to avoid payment of a $15+ million FBAR penalty: what happens if …
Ruesch v. Commissioner, 154 T.C. No. 13 (2020)(link to case in Google Scholar) is the first Tax Court opinion that analyzes the IRS’s ability to certify “seriously delinquent tax debts” to the …
Aspro, Inc. v. Commissioner, T.C. Memo 2021-8 (January 2021) is a cautionary tale for C corporations that look to zero out taxable income through post hoc management fees. In total the three …
In Grajales v Commissioner, 156 T.C. No. 3 (2021), the Tax Court held the 10% tax in section 72(t) applicable to early distributions from qualified retirement plans is not subject to § …
In Ramey v Commissioner, 156 T.C. No. 1 (2021) (available in Tax Notes free resources here), the IRS mailed a final notice of intent to levy (LT11) to the taxpayer’s last known …
Overview of IRS Rev. Proc. 2020-20 Rev. Proc. 2020-20 (link) provides certain qualifying non-resident aliens some administrative relief for certain extended stays in the U.S. caused by travel disruptions arising during the …
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