Our Blog

Steven Toscher Quoted in Tax Notes Article on Receiving Non-Prosecution Letters From DOJ

DESPITE LESS CERTAINTY, SWISS BANK NON-TARGET LETTERS VALUABLE Published by Tax Analysts, Tax Notes Today Although some practitioners question the potential value of non-target letters available to institutions in categories 3 and 4 of the Justice Department’s Swiss bank program, others point out the value of non-target letters in the general criminal context and the request for the … Continue reading Steven Toscher Quoted in Tax Notes Article on Receiving Non-Prosecution Letters From DOJ

Read More

Steven Toscher Quoted in Tax Notes on Proposed Changes to FBAR rules

FBAR CHANGES TRY TO BALANCE COMPLIANCE BURDEN, ENFORCEMENT. Published by Tax Analysts(R) A new proposal from Treasury’s Financial Crimes Enforcement Network regarding the filing of Form 114, “Report of Foreign Bank and Financial Accounts,” would substantially change what is required of some financial professionals who file the foreign bank account reports as part of their … Continue reading Steven Toscher Quoted in Tax Notes on Proposed Changes to FBAR rules

Read More

Judge L. Paige Marvel has been elected as Chief Judge of the United States Tax Court

UNITED STATES TAX COURT Washington, D.C. 20217 February 29, 2016 PRESS RELEASE The United States Tax Court announced today that Judge L. Paige Marvel has been elected as Chief Judge of the United States Tax Court to serve a 2-year term beginning June 1, 2016.  The election of the Chief Judge by the Judges of … Continue reading Judge L. Paige Marvel has been elected as Chief Judge of the United States Tax Court

Read More

If You Want to Recover Costs in Fighting the IRS, Ask on Time By Robert S. Horwitz

Internal Revenue Code sec. 7430, a taxpayer can recover administrative and litigation costs, including attorney fees, if the taxpayer is the prevailing party and the IRS’s position was not substantially justified. There is one hitch: you have to ask for costs and fees before it’s too late.  This is what the taxpayers learned in Foote … Continue reading If You Want to Recover Costs in Fighting the IRS, Ask on Time By Robert S. Horwitz

Read More

IRS Employment Tax Notices Must be Sent to the “Last Known Address” of the Taxpayer, by ROBERT S. HORWITZ

The IRS has recently enhanced their focus on employment tax enforcement throughout the country. An employment tax return filed by April 15 of the year following that in which the applicable quarter falls is “deemed filed” on April 15 of the following year. Where no return is filed, the three-year assessment period does not begin to run … Continue reading IRS Employment Tax Notices Must be Sent to the “Last Known Address” of the Taxpayer, by ROBERT S. HORWITZ

Read More

“GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino and Lawrence A. Sannicandro

ANOTHER GREAT ARTICLE FROM AGOSTINO & ASSOCIATES!!  – To download a great article prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ (www.agostinolaw.com), see the Agostino & Associates February Newsletter – http://files.ctctcdn.com/f7d16a55201/5f66c5a0-157c-4050-bbdd-81087e8b2275.pdf “GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino, Esq. and Lawrence A. … Continue reading “GOTCHA” — UNANTICIPATED AUDIT ISSUES AFTER QUIET DISCLOSURES By Frank Agostino and Lawrence A. Sannicandro

Read More

IRS Transaction Codes Pocket Guide – Helpful if You Need it ! by Robert Horwitz

The IRS transaction codes are typically listed on an taxpayers transcript of account. The transaction guide identifies many of the most often used codes. “This document is an abbreviated version of the Transaction Codes listed in Document 6209 for quick reference. The transaction codes consist of three digits. They are used to identify a transaction … Continue reading IRS Transaction Codes Pocket Guide – Helpful if You Need it ! by Robert Horwitz

Read More

IRS’ Breach of a Closing Agreement – 9th Circuit Sends Al Davis Home by Lacey Strachan

In the recent decision Davis v. United States, No. 13-16458 (9th Cir. 1/25/2016), the Ninth Circuit reversed a district court decision that had invalidated certain IRS assessments against Al Davis and his wife, relating to a TEFRA partnership proceeding involving the Oakland Raiders, a California limited partnership of which Al Davis had the largest interest. … Continue reading IRS’ Breach of a Closing Agreement – 9th Circuit Sends Al Davis Home by Lacey Strachan

Read More

IRS Revises Streamlined FBAR Reporting Procedures Non-Resident Certification Form 14653

The Streamlined Filing Compliance Procedures represent an IRS effort to find a viable method of encouraging U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.[i] The Streamlined Procedures require the filing of original or amended tax returns and FBARs as well as … Continue reading IRS Revises Streamlined FBAR Reporting Procedures Non-Resident Certification Form 14653

Read More

Even If You Pay Your Taxes on Time You Can Still Be Penalized by Robert S. Horwitz

Justice Oliver Wendell Holmes once wrote, “Men must turn square corners when they deal with the Government.” When you deal with the IRS, deviation from the requirements of the Internal Revenue Code and regulations can be costly, as a bank learned the hard way in Commerce Bank & Trust Co. v. United States, 2016 TNT … Continue reading Even If You Pay Your Taxes on Time You Can Still Be Penalized by Robert S. Horwitz

Read More

9100 Relief for Late Portability Elections by Krista Hartwell

Treasury recently updated the section 2010 Regulations to permit the IRS to grant 9100 relief for late portability elections. On January 2, 2013, President Obama signed into law the American Tax Relief Act of 2012 (ATRA), which made permanent portability between spouses of the estate tax annual exclusion amount. Portability allows the second to die … Continue reading 9100 Relief for Late Portability Elections by Krista Hartwell

Read More

Uncle Sam Collects Danish Taxes-The World is Becoming a Smaller Place By Steven Toscher and Robert Horwitz

A recent opinion by the U.S. District Court in the Northern District of Georgia in Dileng v. Commissioner, 1:15-CV-1777-WSD (ND GA) (January 15, 2016), suggests a new era in international tax enforcement.  The opinion discusses the Internal Revenue Service’s (“IRS”) effort to collect Danish taxes pursuant to the Convention for the Avoidance of Double Taxation … Continue reading Uncle Sam Collects Danish Taxes-The World is Becoming a Smaller Place By Steven Toscher and Robert Horwitz

Read More