On July 26th, U.S. Tax Court Judge Lauber issued an opinion in George S. Harrington v. Commissioner, upholding the IRS’ determinations that the taxpayer fraudulently underreported his offshore income and the civil...
In previous blog posts I have discussed the late filing penalty and the reliance on a tax professional defense to the penalty. We discussed the reliance defense with respect to a late estate tax return (HERE) and (HERE) and...
These days it seems like the government taxes everything it can. While it is debatable whether or not that is true, there are a number of “hidden” taxes of which many taxpayers are unaware. Taxes on wagers and...
On July 13, 2021, the Second Circuit issued an opinion in United States v. Kahn, No. 19-3920 (2d Cir. 2021) affirming the trial court’s grant of summary judgment against the defendants for FBAR penalties, plus...
Among the various bills that became law in the 87th Texas Legislature of 2021 are two amendments to the Texas Tax Code that will significantly impact the procedures available for challenging the denial of tax refund claims...
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