Internal Revenue Code section 4980D imposes a $100.00 per day per employee excise tax on any employer that fails to meet certain group health plan requirements. In testimony before the Senate Finance Committee, a policy...
In U.S. v. Sperrazza, the U.S. Eleventh Circuit recently affirmed the conviction of a Georgia physician who was convicted of three counts of tax evasion, in violation of 26 U.S.C. § 7201, and two counts of structuring...
After a taxpayer fails to remit payment on an outstanding tax liability and the IRS issues a demand for payment, the Internal Revenue Code imposes a statutory lien in favor of the government on all property and property...
On July 31, 2015, President Obama signed into law H.R. 3236, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.” In addition to providing a 3-month, stop-gap reauthorization of the...
In Moore v. U.S., No. C13-2063 (W.D. Wash. July 24, 2015), Judge Richard Jones examined a case in which FBAR penalties of $10,000 were assessed for each year from 2005 through 2008. The Court held the IRS’s...
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