A blast from the past just came across the headlines recently surrounding a member of the hit show of 2009, Jersey Shore. I had previously covered […]
Those with unreported foreign/offshore accounts and unfiled FBARs should act fast to take advantage of willful penalty protection and immunity offered by the OVDP, especially if […]
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION UNITED STATES OF AMERICA, -vs- DOMINIQUE G. COLLIOT, Defendant. CAUSE NO.: AU-16-CA-01281-SS […]
Wadhan v. United States – Another District Court Opinion Following Colliot and Limiting FBAR Penalty
1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Marcia S. Krieger Civil Action No. 17-CV-1287-MSK UNITED STATES OF AMERICA, Plaintiffs, […]
Blogger’s Note: It appears to me the trial-level judge in the Court of Federal Claims has determined the regulation at issue is invalid because it […]
What is a Choate Lien? A choate lien means a lien where “the identity of the lienor, the property subject to the lien, and the amount […]
A recent release by the United States Department of Justice covered a $50 million-dollar judgement against two individuals and two companies. The full release can be […]
T.C. Memo. 2018-184 UNITED STATES TAX COURT W.T. SNIPES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27902-15L. Filed November 1, 2018. P has […]
When a Federal tax lien for one person is erroneously filed against another person’s property, that tax lien may cause an escrow company to pay the […]
Under 26 U.S.C. § 6532(a)(1), a taxpayer generally may not wait longer than 2 years from the issuance of the IRS’s disallowance of the administrative […]