Resources

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.

In a prior blog post, we discussed the case of Dr. Robert McClendon and the IRS’ assessment of the Trust Fund Recovery Penalty against him due to his attempt to do the right thing. In 2016, a U.S. District Court...