Category Archives: POLICY

ON FBAR WILLUL NON-FILING AND WILLFUL BLINDNESS – THE RUMSFELD DISCLAIMER

In United States v. Williams, (2012), the Fourth Circuit Court of Appeals reversed the District Court’s holding that Williams’ failure to file an FBAR that was due June 30, 2001 was a non-willful failure to file because the government already … Continue reading

Posted in 2012 OVDP, FBARS, JOINT RETURNS, NEW OVDP, OFFSHORE BANK ACCOUNTS, POLICY, RETURNS, TAX | Tagged , , , , , , , , | Leave a comment

IRS FIRST TIME ABATE POLICY PROVIDES PENALTY RELIEF IN CERTAIN SITUATIONS

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

THE GOOD, THE BAD AND THE UGLY: The Taxpayer Relief Act of 2012

When I first read the title of the Act I thought immediately of Jonathan Swift’s satirical essay, “A Modest Proposal for Preventing the Children of Poor People From Being a Burden to Their Parents or Country, and for Making Them … Continue reading

Posted in LEGISLATION, POLICY, TAX, Uncategorized | Tagged , , , , , , , , , | Leave a comment

THE IRS MAY BE WEB SNOOPING ON YOU

Electronic Frontier Foundation (EFF) (www.eff.org) is a donor-funded nonprofit organization that works to defend free speech, privacy, innovation, and consumer digital rights.  Recently, EFF obtained a 2009 IRS training course manual that offers insight into how IRS views various internet … Continue reading

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WARREN BUFFETT SOUNDING LIKE TEDDY ROOSEVELT

In Op Ed published in the New York Times billionaire, chairman and CEO of Berkshire Hathaway, Warren Buffett has thrown some coal on the fire of the debate regarding tax reform.  To the likely chagrin of Tea Party adherents, he … Continue reading

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AMERICAN PIE TURNS INTO AMERICAN BLACK EYE

Standard and Poor’s downgrade of US debt rating by one notch from AAA to AA+ is a hugely important event.  Not that interest rates will sharply rise anytime soon, not that the U.S. will ever default on its bonds – … Continue reading

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WALKING ON THE DEBT CEILING –

POLITICS OR REAL NECESSITY Since 1980 the federal debt ceiling has been increased from $706 billion to $13,529 trillion. These debt ceiling increases correspond with federal debt levels.  Of that increase, 16 debt ceiling increases totaling $3,361 trillion occurred during … Continue reading

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