On January 18, 2019, the U.S. District Court held defendants liable for the willful FBAR Penalty in its opinion in United States v. Horowitz, No. PWG-16-1997 […]
When Can a Court Use Its Discretion to Decline Foreclosure of Property Subject to an IRS Federal Tax Lien? Judicial discretion to decline foreclosure in Federal […]
Application of Homestead Provisions To Keep Your Home in Bankruptcy and Survival of Federal Tax Liens California’s Homestead exemption is found in Chapter 4 of Division […]
Does Res Judicata Apply to Stipulated U.S. Tax Court Decisions? The judicial principle of res judicata applies to stipulated Tax Court Decisions. However, if the stipulated […]
What Is an IRS Tax Assessment? An IRS tax assessment is a bookkeeping entry made by the Internal Revenue Service when an IRS assessment officer signs […]
The big news last week was that the Department of Justice lost two high-profiled trials involving offshore bank accounts. The first was a jury verdict of […]
The U.S. Department of Justice and the United States Attorney’s Office for the Central District of California announced today another guilty plea in an FBAR case, this […]