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...
Taxpayers should be aware that the IRS’s test program for streamlined installment agreements is set to expire at the end of September 2018—just one month away. Under the test program, taxpayers may not be required to...
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