How to Handle Foreign Informational Form Penalties
It was approximately two years ago when the tax law equivalent of a 7.0 earthquake came in the form of a decision from the United States Tax Court when it issued its decision in the case of Farhy v. Commi... David Woods, EA, USTCP, NTPI Fellow®
Say Goodbye to Most Form 5471 Penalties
Alon Farhy used two Belize corporations to attempt to evade United States income tax. While he was not prosecuted for these actions, he also never filed Form 5471, Information Return of U.S. Persons With Respect to Certain Fore... Thomas Gorczynski, EA, USTCP
Assessable Penalties and Abating Them
The United States federal tax system operates on a system of somewhat voluntary compliance. However, human nature being what it is, a voluntary system without a means of enforcement lends itself to fraud, ignorance, and disregard. I... David Woods, EA
What Jurisdiction Does the Tax Court Have Over Passport Actions Under §7435(b)?
Vivian Ruesch, Petitioner v. Commissioner of Internal Revenue, Respondent 154 T.C. 13 | Filed June 25, 2020 Vivian Ruesch (154 T.C. 13 (6/25/20)) provides the first Tax Court guidance on Internal Revenue Code (IRC) §7345, captioned “Revocat... Sherrill Trovato, EA, USTCP