Category Archives: DELINQUENT RETURN

IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

Posted on February 26, 2015 by taxpenaltylawyer

On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.”  On the Webinar panel were two IRS officials:  David W. Horton, Director, IRS International Individual Compliance; and John C. McDougal, … Continue reading →

Posted in 2014 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , | 8 Comments

MORE ON RETURNS OF SAME-SEX COUPLES

Posted on September 11, 2013 by taxpenaltylawyer

It is noteworthy that the IRS announced new rules for same-sex couples  (Rev. Rul. 2013-17) discussed in my post of 9/3/2013 (IRS Issues Rules for Same-Sex Couples) applies to original or amended tax returns filed on or after September 16, 2013.  This means … Continue reading →

Posted in AMENDED RETURNS, COMPLIANCE, DELINQUENT RETURN, JOINT RETURNS, RETURNS, TAX | Tagged , , , , , , | Leave a comment

OVDP OR NOTHING AT ALL

Posted on July 14, 2013 by taxpenaltylawyer

The 1939 song, “All or Nothing at All,” (by Arthur Altman and Jack Lawrence) made popular by Frank Sinatra might be sung in a new version by IRS, “OVDP or Nothing at All.” The Bank Secrecy Act contains draconian penalties … Continue reading →

Posted in 2012 OVDP, AMENDED RETURNS, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | Leave a comment

WHAT CONDUCT WILL TRIGGER THE 75% CIVIL FRAUD PENALTY OF IRC SECTION 6663?

Posted on June 4, 2013 by taxpenaltylawyer

 In Ward v. Commissioner, T.C. Memo. 2013-133 (May 29, 2013), Mr. Ward sought redetermination of an IRS proposed deficiency on a number of grounds. This post addresses only his disputation of the civil fraud penalty proposed.  Judge Kerrigan’s decision contains … Continue reading →

Posted in COMPLIANCE, DELINQUENT RETURN, TAX | Tagged , , , , , | Leave a comment

IRS FIRST TIME ABATE POLICY PROVIDES PENALTY RELIEF IN CERTAIN SITUATIONS

Posted on June 1, 2013 by taxpenaltylawyer

The IRS today clarified its policy with regard to abatement of certain penalties for first time offenders.  The policy was modified to clarify that relief applies only where the taxpayer is current with all tax filings and tax payments. See IRM … Continue reading →

Posted in COMPLIANCE, DELINQUENT RETURN, EMPLOYMENT TAXES, IRS COLLECTIONS, POLICY, RETURNS, TAX, TRUST FUND PENALTY, UNFILED RETURNS | Tagged , , , , , , , | 6 Comments

IRS TO GET MORE EASY PICKINGS OF OFFSHORE FRUIT

Posted on March 23, 2013 by taxpenaltylawyer

Two high level IRS Criminal Investigation (CI) officials participated an American Bar Association, Tax Section, Webinar, “Criminal Tax Enforcement Hot Topics: The IRS Perspective,” (March 20, 2013).  Edward “Ted” Cronin is the Division Counsel/ Associates Chief Counsel (Criminal Tax) … Continue reading →

Posted in 2012 OVDP, AMENDED RETURNS, COMPLIANCE, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , | Leave a comment

STILL OUT IN THE COLD? IRS LEAVES OPEN DOOR FOR VOLUNTARY DISCLOSURE – 2012 OVDP

Posted on August 6, 2012 by taxpenaltylawyer

As Global Warming is said to be melting the arctic glaciers, safe havens for offshore tax scofflaws are dwindling from increasingly strident global economic pressure applied to tax haven jurisdictions. Now, tax haven countries wishing to participate in the global … Continue reading →

Posted in 2012 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

THERE ARE NO MAGIC TRICKS FOR RESOLVING TAX DEBTS OF THE NON-FILER: CAUTION NOT SPEED SHOULD BE THE WATCH WORD.

Posted on April 17, 2012 by taxpenaltylawyer

Booker T. Washington said, “Nothing ever comes to one that is worth having, except as a result of hard work.”  There is no easy solution to resolving tax debts.  Anyone who claims to be able to eliminate tax debts quickly … Continue reading →

Posted in DELINQUENT RETURN, INNOCENT SPOUSE, IRS COLLECTIONS, RETURNS, TAX, TAX CRIMES, UNFILED RETURNS | Tagged , , , , | Leave a comment