Earlier this year, the U.S. Tax Court in The Estate of Howard V. Moore v. Commissioner reminded every taxpayer that while estate planning is important, to achieve the intended estate tax benefits, traps must be...
[This blog has been updated as of June 1, 2020.] [This Blog Post has been updated to reflect the issuance of IRS Notice 2020-23.] As mentioned in a previous blog post, IRS Notice 2020-18 provides an...
On May 29, 2020, the Treasury Inspector General for Tax Administration (TIGTA) issued a report entitled,“High-Income Nonfilers Owing Billions of Dollars Are Not Being Worked by the Internal Revenue Service”. The report...
On May 29th, the U.S. Tax Court announced it will be conducting remote trial sessions until further notice, joining many other courts around the country. A short press release announcing remote trial sessions is HERE....
After a string of government victories in willful FBAR penalty cases, there may be some light at the end of the tunnel for taxpayers challenging an assertion of a willful FBAR penalty. In United States v. Sandra J. de...
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