Resources Archive
October 1, 2018
Dallas Bar Association Tax Section... [ read ]
September 28, 2018
Tax Court Sends Another Sobering Reminder to Taxpayers: Carefully Review Your Tax Return Before Filing...
[ read ]
The Tax Court made itself loud and clear again in its recent decision Yapp v. Commissioner: carefully review your return before filing even if a professional is used to prepare the return. A failure to do so can have drastic consequences down the road.
September 25, 2018
Western States Association of Tax Administrators (WSATA)... [ read ]
September 25, 2018
Metroplex Practice Management Group (MPMG)... [ read ]
September 24, 2018
How to Respond to an IRS Backup Withholding Notice...
[ read ]
The Internal Revenue Code provides that if a business files an information return that has a missing or incorrect Taxpayer Identification Number (TIN), the business will be notified by the IRS and may be required to withhold a specified percentage (24% for payments made after 12/31/17) of certain reportable payments made to the payee with the missing or incorrect TIN. Businesses that ignore the IRS notices and fail to comply may be responsible for uncollected taxes and face penalties for filing incorrect information returns.
September 20, 2018
Information Reporting Penalty and the Reasonable Cause Defense...
[ read ]
Forms W-2 are subject to information reporting penalties under Sections 6721 and 6722 of the Internal Revenue Code. Section 6721 imposes a penalty for any failure to file an information return timely, for any failure to include all required information, or for the inclusion of incorrect information. Section 6722 imposes a penalty in the case of any failure to furnish a payee statement on or before the required date, any failure to include the required information, or the inclusion of incorrect information.
September 14, 2018
IRS Collection and Retirement Accounts...
[ read ]
Pursuant to IRC Section 72(t)(1), if a taxpayer receives a distribution from a qualified retirement account, the taxpayer not only faces potential taxes on the distribution amount itself, but also an additional tax equal to 10% of the amount of the distribution that is includible in gross income. There are a number of exceptions to the 10% rule, most notably distributions made after the taxpayer has reached the age of 59 ½.
Septmeber 12, 2018
Does Failure to Oversee A Trusted Employee Equal Willful Conduct for the Trust Fund Recovery Penalty?...
[ read ]
In prior blog posts, we discussed the McClendon case where a doctor made a loan to his business to make payroll, and in doing so, inadvertently exposed himself to liability for the trust fund recovery penalty. The 5th Circuit recently returned the case to the U.S. District Court for further consideration, including the Government's argument that the doctor's failure to oversee the trusted employee to whom he delegated the duty of filing payroll tax returns and paying the employment taxes satisfies the willfulness element of IRC Section 6672.
September 11, 2018
Constructive Knowledge Not Enough for FBAR Willfulness...
[ read ]
Josh Ungerman was quoted in the Tax Notes article, "Constructive Knowledge Not Enough for FBAR Willfulness" 2018 TNI 36-34.
Septmeber 11, 2018
Court Finds FBAR Penalty Can Exceed $100,000...
[ read ]
Josh Ungerman was quoted in the Tax Notes article, "Court Finds FBAR Penalty Can Exceed $100,000" 2018 TNI 33-40.
Page 69 of 100
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