Penalties

Form 5471, Penalties, Tax Court

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

By Matthew L. Roberts Apr 12, 2023
Penalties, Section 6751

IRS Issues Proposed Regulations under Section 6751(b)

By Matthew L. Roberts 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 Matthew L. Roberts Jul 19, 2022
Penalties, Tax Litigation Insights

IRS Tax Penalties and the Tax Professional Reliance Defense

By Matthew L. Roberts May 23, 2022
Penalties, Section 6751

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
International Tax, Penalties

Defenses to Section 6038 IRS Penalties

By Matthew L. Roberts 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 Matthew L. Roberts 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
Cross-Border Tax Insights, FBAR, International Tax, Penalties

FBAR Penalties: Another Court Holds that FBAR Penalties Can Exceed the Regulatory Ceiling

By Jason B. Freeman Jul 29, 2021
Penalties, Tax Court

Ill and Illiterate | Torres v. Commissioner

By Freeman Law Jun 15, 2021
Penalties, Tax Court, The-Tax-Court-in-Brief Insights

Tax Court Case Addresses Reasonable Cause Standard and Tax Penalties

By Freeman Law May 10, 2021
Penalties, Tax Exempt

Does the IRS’ First Time Abatement Rule Apply to Tax-Exempt Organizations?

By Matthew L. Roberts Apr 28, 2021
Penalties

How to Successfully Request IRS Penalty Relief

By Matthew L. Roberts Feb 03, 2021