Penalties

Form 5471, Penalties, Tax Court

The IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

By Jason B. Freeman Apr 12, 2023
Penalties, Section 6751

The IRS Issues Proposed Regulations under Section 6751(b)

By Jason B. Freeman Apr 11, 2023
Defenses, Penalties

Section 6751(b) Penalty Approval Circuit Split

By Freeman Law Dec 13, 2022
Employment Tax, Penalties

How to Successfully Fight the Section 6721(e) Intentional Disregard Penalty

By Jason B. Freeman Jul 19, 2022
Penalties, Tax Litigation Insights

IRS Tax Penalties and the Tax Professional Reliance Defense

By Jason B. Freeman May 23, 2022
Penalties, Section 6751

Ninth Circuit Opines on Section 6751(b) and its Application to Assessable Penalties

By Jason B. Freeman Apr 07, 2022
Administrative Procedure Act, Penalties, White-Collar Defense Insights

IRS Notice 2007-83 Declared Unlawful Under the Administrative Procedure Act

By Jason B. Freeman Mar 08, 2022
IRS Collection, Penalties, Voluntary Disclosure

The IRS’s Voluntary Disclosure Practice (VDP): IRS Revises Form 14457

By Jason B. Freeman Feb 16, 2022
Penalties, Section 6751, Tax Court

Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code Section 6751(b)(1)

By Cory Halliburton Jan 27, 2022
Fraud, Penalties, Tax Litigation Insights

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

By Jason B. Freeman Dec 20, 2021
Innocent Spouse Relief, IRS Collection, Penalties, Tax Court

Tax Court Grants Innocent Spouse Relief

By Jason B. Freeman Dec 19, 2021
Cross-Border Tax Insights, International Tax, Penalties, Tax Court

Defenses to Section 6038 IRS Penalties

By Jason B. Freeman Oct 20, 2021
Penalties, Tax Court, Tax Litigation Insights

Accuracy-Related Penalties: The Burdens of Proof and Production

By Freeman Law Sep 14, 2021
Penalties, Preparer Penalties

Section 6700 Penalties – False or Fraudulent Statements

By Freeman Law Sep 01, 2021
Penalties, Trust & Estate Litigation

Reasonable Cause: An Estate’s Defense Against IRS’s Late-Filing Penalties

By Jason B. Freeman Aug 19, 2021
Penalties, Qualified Amended Return

Qualified Amended Returns: How to Avoid Tax Penalties

By Jason B. Freeman Aug 12, 2021
Form 8275, IRS Disclosure, Penalties

The Art of the Tax Disclosure: How to Avoid Tax Penalties By Disclosing a Return Position

By Jason B. Freeman Aug 04, 2021
Cross-Border Tax Insights, FBAR, International Tax, Penalties

Do FBAR Penalties Survive Death? A Texas Court Says “Yes”

By Jason B. Freeman Jul 31, 2021