Category Archives: POLICY

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

Posted on April 23, 2014 by taxpenaltylawyer

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

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

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

Posted on January 22, 2013 by taxpenaltylawyer

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

Posted on July 9, 2012 by taxpenaltylawyer

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 →

Posted in AUDITS, POLICY, TAX | Tagged , , , , | Leave a comment

WARREN BUFFETT SOUNDING LIKE TEDDY ROOSEVELT

Posted on August 16, 2011 by taxpenaltylawyer

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

Posted on August 10, 2011 by taxpenaltylawyer

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 –

Posted on July 28, 2011 by taxpenaltylawyer

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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WHERE HAVE ALL THE WISE MEN GONE?

Posted on July 6, 2011 by taxpenaltylawyer

GREATNESS IN AMERICANS I had recently watched the movie “1776” a musical rendering of the hard work and compromise that preceded signing of our Declaration of Independence.” Reading the latest grim news about the debt ceiling stalemate, I started thinking … Continue reading →

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