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Have a Bankruptcy Judge Review Your Tax Fraud Penalty
Civil tax fraud penalties are 75% of the underpayment of tax attributable to tax fraud. Whenever the IRS believes that a taxpayer has intentionally violated a known legal duty, these penalties can be...
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The Substitute Return: When the IRS Files Unfiled Returns For You
If you fail to file your tax return when you have a legal obligation to do so, the IRS can use the Substitute for Return (SFR) procedure to file it for you. There are several disadvantages to this...
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The Elements of Tax Evasion
Tax evasion can be shown when the following three elements are present: The existence of a tax deficiency An attempt to evade or defeat tax Continue reading
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Former IRS Revenue Officer Gets Prison Time for Tax Evasion
A former IRS revenue officer used his knowledge of the tax system to evade more than $573,000 in taxes over a 16-year period. Henti Lucian Baird hid his income—which was ironically made as a tax...
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South Carolina Bank Involved in Employment Tax Fraud Scheme
The former Vice President of a South Carolina-based bank has pleaded guilty to conspiring to defraud the United States by participating in an employment tax fraud scheme that resulted in over $1...
View ArticleDon’t Jump at the Chance to go to IRS Appeals Directly from a Tax Audit
In a 2019 U.S. Tax Court case, Palmolive Building Investors, LLC v. Commissioner, 152 T.C. No. 4, (2019) (Palmolive II), the Tax Court held that both penalties determined by the Revenue Agent in a tax...
View ArticleNot Just Another Covid-19 Announcement
Some of you may be concerned about the impact of the Coronavirus aka Covid-19 outbreak on your taxes, and those of your clients. The news from the IRS has been slow in coming. On Friday of last week...
View ArticleNot Just Another Covid-19 Announcement (Part II)
On Tuesday evening our tax lawyers sent out an announcement discussing some of the tax filing and payment implications of the Covid-19 virus. We indicated that Secretary of Treasury Mnuchin had...
View ArticleSBA Publishes Loan Forgiveness Form and Instructions for PPP Loans
Most, if not all, Payroll Protection Program (PPP) borrowers are focused on the question of whether they will be able to have their PPP loan forgiven. Many questions have arisen, and some but not all,...
View ArticleOur Tax Attorneys Have Good News if you Didn’t Apply for a PPP Loan by the...
PPP Loans are an excellent way for small businesses with Covid-19 related financial issues to obtain a very low (one percent) interest loan from the government. Unfortunately, if you haven’t applied...
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