By Caroline Rule The CPA Journal December 2017 Edition Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is frequently unclear, yet penalties for a failure to file can be severe.
By Caroline Rule ABA Section of Litigation November 2017 Edition Most federal district court judges are accustomed – even in this age of “advisory” U.S. Sentencing Guidelines (Guidelines or U.S.S.G.) – to sentencing a criminal defendant by first calculating the applicable “Offense Level,” which provides for
By Kevin M. Flynn The CPA Journal November 2017 Edition Under Internal Revenue Code (IRC) section 6672(a), an individual can be held personally liable for a penalty for the willful failure to collect, account for, and pay to the IRS the employment taxes of a business.
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in
By Jerald David August Journal of Passthrough Entities September – October 2017 Edition In McKelvey, the executor of the taxpayer’s estate petitioned for a redetermination of the $41.26M deficiency in income tax for 2008, processed by the IRS, attributable to his entering into various variable prepaid forward
