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...
IRS Collection and Retirement Accounts 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...
In prior blog posts (here) and (here) 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...
Josh Ungerman was quoted in the Tax Notes article, “Constructive Knowledge Not Enough for FBAR Willfulness” 2018 TNI 36-34.
Josh Ungerman was quoted in the Tax Notes article, “Court Finds FBAR Penalty Can Exceed $100,000” 2018 TNI 33-40.
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