Collection Due Process Hearing News Today

U.S. Tax Court ruled in Farhy v. Commissioner IRS lacks statutory authority to assess Form 5471 penalties. IRS cannot proceed with collection of penalties against taxpayer. Farhy may have implications for taxpayers who have paid or are contesting Form 5471 penalties.

When it comes to IRS international reporting of foreign accounts, assets, investments, and income, one of the key factors motivating taxpayers to get…

When a Taxpayer has been penalized by the Internal Revenue Service, they have the opportunity to try to seek removal of those penalties by showing…

While the Internal Revenue Service has many different tools and weapons available to facilitate the enforcement of tax debts and liabilities, one of…

When US Taxpayers are assessed additional taxes or penalties (especially international information reporting penalties) by the Internal Revenue…

In recent years, the Internal Revenue Service has significantly increased enforcement of the Form 3520-A Reporting Requirements. Under the Internal…

BM Construction v. Comm’r, T.C. Memo. 2021-13 | February 8, 2021 | Urda, J. | Dkt. No. 24352-17L Short Summary: The IRS initiated an examination of the tax liabilities associated with Mr. Bernotas and his sole proprietorship, BM Construction. After issuing an initial report on May 7, 2014, the examination officer issued two Letters 950-D: (1) to Mr. Bernotas with respect to his income taxes on June 6, 2014; and (2) to BM Construction with respect to backup withholding tax liabilities on June ...