View Post

Federal District Court Holds Passport Revocation Statute Constitutional

In Penalties by Matthew RobertsLeave a Comment

Comparatively speaking, Section 7345 is a relative newcomer to the Code.  Enacted in late 2015 as part of the Fixing America’s Surface Transportation Act (“FAST Act”), it permits the Government to deny U.S. passport applications or revoke already issued passports if a taxpayer has a federal income tax debt that is “seriously delinquent.” Last year, during a Treasury Inspector General …

View Post

Tax Court Determines §6672 Penalties are Penalties Subject to §6751(b) Requirements

In 6751, Penalties, Trust Fund Penalty by Jason B. FreemanLeave a Comment

In Chadwick v. Commissioner, a recent collection due process hearing (CDP) case, the United States Tax Court upheld an IRS notice of intent to levy. Chadwick v. Comm’r, 154 T.C. No. 5 (2020) stemmed from the taxpayer’s failure to pay employment taxes for two LLC entities for which he was responsible and the subsequent assessment of trust fund recovery penalties …

View Post

International Reporting Penalties

In FBAR, Fines, International Tax, Penalties, Uncategorized by Ryan DeanLeave a Comment

Taxpayers with interests in foreign financial assets, financial accounts, and/or foreign trusts may have certain tax reporting obligations with the IRS.  For example, taxpayers with a financial interest in or signature authority over foreign financial accounts with an aggregate value of over $10,000 at any time during the calendar year must file a Report of Foreign Bank and Financial Account …

View Post

IRS Increasing Enforcement of Syndicated Conservation Easements

In Penalties by Jason B. FreemanLeave a Comment

A recent IRS press release announced a significant increase in enforcement actions focused on syndicated conservation easement transactions. The IRS announced that these transactions are a “priority compliance area for the agency.” The enforcement actions are directed as “coordinated examinations” across various divisions of the IRS.   The Criminal Investigation Division has initiated separate investigations as well. All told, the …

View Post

The Willful FBAR Penalty: Bedrosian and New Insights

In FBAR, Penalties by Jason B. FreemanLeave a Comment

The Third Circuit Court of Appeals recently issued its much-anticipated decision in Bedrosian v. United States.  The opinion reviewed a lower court’s decision refusing to apply the willful FBAR penalty.  See our prior post on the case here.  The appellate court’s decision ultimately remanded the case back to the lower court for further analysis.   The FBAR Reporting Requirement:  Congress …