Category Archives: STATUTE OF LIMITATIONS

WHAT SHOULD YOU DO? YOU FAILED TO FILE AN FBAR BUT REPORTED ALL INCOME FROM AN OFFSHORE ACCOUNT

Posted on July 24, 2014 by taxpenaltylawyer

This predicament is not an uncommon occurrence.  Many taxpayers may have had a foreign bank or brokerage account and reported the income in their tax returns or earned no income but did not know they had to file an FBAR.  … Continue reading →

Posted in 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STATUTE OF LIMITATIONS, TAX | Tagged , , , , , , | 42 Comments

FILING BANKRUPTCY BEFORE SEEKING INNOCENT SPOUSE RELIEF ON IRS CLAIM ENDS IN DISMISSAL OF BANKRUPCY CASE AT REQUEST OF DEBTOR

Posted on August 3, 2013 by taxpenaltylawyer

Pearl Dwek filed for bankruptcy under Chapter 13.  Before the Court had confirmed her plan, she filed a motion to modify the stay to extend the period of her payment plan to allow her to proceed in U.S. Tax Court … Continue reading →

Posted in INNOCENT SPOUSE, IRS COLLECTIONS, STATUTE OF LIMITATIONS, TAX, TRUST FUND PENALTY | Tagged , , , , , , , , , | Leave a comment

INNOCENT SPOUSE CASE OF THE MONTH – U.S. V. CHARLES LEBEAU; VITORIA LEBEAU, ET. AL., (CASE NO. CV817 BTM(NLS), USDC, S.D. CA, MARCH 12, 2012)

Posted on June 16, 2012 by taxpenaltylawyer

 This is another lower court case not precedential, but having some interesting aspects and leaning value.  The District Court granted the U.S.’s Motion for Partial Summary Judgment in its suit to obtain a judgment against the named defendants and Charles … Continue reading →

Posted in DIVORCE, INNOCENT SPOUSE, STATUTE OF LIMITATIONS, SUITS TO COLLECT TAX, TAX | Tagged , , | Leave a comment

INNOCENT SPOUSE CASE OF THE MONTH – U.S. v. MARY ELIZABETH MILES, ET AL. (NO. CV 10-2398 CW., US. District Court, N.D. California, March 30, 2012)

Posted on May 6, 2012 by taxpenaltylawyer

This is another lower court case not particularly significant as precedent but having some interesting aspects and leaning value. The District Court granted theU.S.’s Motion for Summary Judgment in its suit to obtain a judgment against defendant Mary Miles’ in … Continue reading →

Posted in DIVORCE, DURESS, EQUITABLE RELIEF, INNOCENT SPOUSE, STATUTE OF LIMITATIONS, SUITS TO COLLECT TAX, TAX, Uncategorized | Tagged , , , , , | Leave a comment