Monthly Archives: September 2014

BLOOMBERG BNA SAMPLES ATTORNEY VIEWS ON STREAMLINED PROCESS

Posted on September 20, 2014 by taxpenaltylawyer

Alison Bennett of Bloomberg BNA’s article “Questions surround Standard of Willful Path Conduct under Streamlined Version of OVDP” (9/17/14), summarizes some of her interviews with tax lawyers around the country concerning the Streamlined Filing Compliance Procedures announced by IRS on … Continue reading →

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DIVORCE DECREE TRUMPS FEDERAL TAX LIEN ARISING AFTER ENTRY OF DIVORCE JUDGMENT.

Posted on September 15, 2014 by taxpenaltylawyer

A New Hampshire U.S. District Court decision U.S. v. Baker 13-cv-213-PB2014 DNH 176, August 22, 2014) highlights some important lessons about the priorities of a divorce decree against a federal tax lien on one of the spouses. The facts of … Continue reading →

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WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE

Posted on September 1, 2014 by taxpenaltylawyer

“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia).  Most clients with unreported offshore accounts who … Continue reading →

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