More than 10,000 taxpayers showed signs of having avoided offshore penalties by making “quiet disclosures” of foreign bank accounts for tax years 2003 through 2008, the U.S. Government Accountability Office (GAO) reported, a period for which the IRS has detected several hundred quiet disclosures. Filing data also suggest many more
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TOPICS / TAX
IRS practice & procedure
CPA’s nonfiling ruled inadmissible for abusive shelter promotion penalty
Evidence of a CPA’s failure to file and pay his own taxes was not properly admissible in determining his penalty for promoting an abusive tax shelter, the Fourth Circuit held. The appellate court thus vacated a $2.6 million penalty and liability verdict against CPA Robert Nagy and reversed and remanded
Automated substitutes for return drop by half
After increasing eightfold from fiscal 2002 to 2011, the number of returns generated by the IRS’s Automated Substitute for Return (ASFR) program fell by half in fiscal 2012, and tax assessments under the program decreased by 54% (see related graphic, “Automated Substitutes for Return Decline”). The ASFR program uses information
Taxpayer can contest trust fund penalty where son tossed Letter 1153 into basement
A taxpayer successfully challenged the IRS’s filing of a notice of federal tax lien against him for a trust fund recovery penalty on the basis that he did not have an opportunity to contest the liability on which the assessment underlying the lien was based. The taxpayer argued he had
Switzerland proposes allowing banks to resolve U.S. tax evasion cases
The government of Switzerland would allow its banks to disclose data about account holders to the U.S. Department of Justice, circumventing its own bank secrecy law, under a bill that will be introduced in the Swiss parliament. The bill aims to create a legal basis under Swiss law to resolve
IRS will not seek taxpayer emails without a warrant
The IRS on Wednesday announced a new policy regarding how it will request emails from internet service providers (ISPs) (IRS Policy Statement 4-120). Under the new policy, the IRS will obtain a search warrant “in all cases when seeking … the content of email communications stored by the ISP.” In
Final regulations permanently extend period to receive disclosure authorization
The IRS on Monday issued final regulations extending from 60 days to 120 days the permitted period for submission of taxpayer authorizations allowing disclosure of returns and return information to third-party designees (T.D. 9618). The regulations, which were adopted without change from the proposed rule issued in March 2011 (REG-153338-09),
GAO: “Quiet disclosures” of foreign accounts potentially much higher than IRS detected
More than 10,000 taxpayers showed signs of having avoided offshore penalties by making “quiet disclosures” of foreign bank accounts for tax years 2003 through 2008, the U.S. Government Accountability Office (GAO) reported, a period for which the IRS has detected several hundred quiet disclosures. Filing data also suggest many more
How can theft prevention, reporting, and return filing be improved?
Changing the April 15 due date, moving taxpayer information to the cloud, and allowing personal identification numbers (PINs) for taxpayers who want them were all on the table at a Thursday hearing held by the IRS Oversight Board to explore ways to combat fraud and improve tax administration. The board,
Final rules require EIN updates
On Friday, the IRS issued final regulations requiring taxpayers that obtain employer identification numbers (EINs) to update their information with the IRS (T.D. 9617). The regulations, which will apply beginning Jan. 1, 2014, to give the IRS time to publish the relevant form and instructions, adopt without change proposed regulations
TIGTA: Noncash charitable contribution claims still often erroneous
The Treasury Inspector General for Tax Administration (TIGTA) estimated that more than 273,000 taxpayers claimed $3.8 billion in potentially erroneous noncash charitable contribution deductions in tax year 2010. The audit report’s findings (Rep’t No. 2013-40-009) echoed TIGTA’s previous examinations of noncompliance in 2007 and 2009. In the latest review, released
Conservation easement tax donation update
The deductibility of a charitable donation for a conservation easement or restriction on a real property interest is provided for under Sec. 170(h). Even with almost 13 pages of regulations (Regs. Sec. 1.170A-14), this provision is not straightforward, as evidenced by the number of taxpayers challenged by the IRS. Careful
Most whistleblower awards still under pre-2006 law
In its latest annual report to Congress on the whistleblower program Feb. 13, the IRS said it received hundreds of submissions during the 2012 fiscal year (FY) that appeared to meet the higher underpayment threshold for enhanced awards, enacted in 2006. Nearly all of the awards paid during the fiscal
When is a casualty “sudden, unexpected, or unusual”?
The Second Circuit’s recent remand of Alphonso, No. 11-2364-ag (2d Cir. 2/6/13), rev’g 136 T.C. 247 (2011) (see “Tax Matters: Co-op Lessee Has Property Interest in Collapsed Wall,” on page 73), allows the Tax Court to consider perhaps the most controversial aspect of casualty loss deductions—the meaning of “sudden, unexpected,
Widow avoids jail time and probation in sentencing for offshore account tax evasion
Wealthy Palm Beach resident Mary Estelle Curran was sentenced to one year of probation in federal district court Thursday, following her guilty plea to charges of tax evasion. However, Judge Kenneth Ryskamp almost immediately revoked that sentence, reportedly telling the prosecutors that he thought the prosecution had been unnecessary and
Boston-area residents get more time to file returns and pay tax
In response to Monday’s bombings at the Boston Marathon, the IRS announced late Tuesday that it is extending the time for filing certain individual tax returns that were due April 15 and paying any tax due until July 15. “Our hearts go out to the people affected by this tragic
Witnesses tell Senate Finance Committee ways to improve tax system
Witnesses gave the Senate Finance Committee a variety of suggestions on how to fight tax identity theft and fraud, reform the tax system, and fund the IRS during a hearing on Tuesday. The committee heard from witnesses representing the IRS, the Taxpayer Advocate Service, the Social Security Administration (SSA), and
Significant decline in IRS staff leads to fewer audits
The Transactional Records Access Clearinghouse (TRAC), reports that the IRS plans to expend 18% fewer staff hours auditing large businesses with assets of more than $10 million in fiscal year 2013 (which ends Sept. 30) than it did in FY 2011. These lower numbers do not take into account the
Appeals court reverses $2.6 million penalty against tax shelter promoter
The Fourth Circuit Court of Appeals reversed and remanded a district court decision because the lower court permitted the jury to hear evidence of a taxpayer’s failure to file his personal income tax returns and to pay his taxes as evidence of his bad acts in determining whether he should
Individual health care mandate rules proposed
The IRS released proposed rules for the Sec. 5000A shared-responsibility payment—the penalty or tax imposed on individual taxpayers who do not obtain minimum essential health care coverage beginning in 2014 (the controversial “individual mandate”) (REG-148500-12). Separately, the IRS also issued final regulations defining affordable coverage for purposes of the premium
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