National Taxpayer Advocate – Pushes for Positive Changes for Americans Abroad

The law requires the National Taxpayer Advocate (NTA) to submit two annual reports to the House Committee on Ways and Means and the Senate Committee on Finance, without any prior review or comment from the Internal Revenue Service. The NTA Report for FY 2025 was just issued and includes various NTA advocacy objectives. Two of the … Continue reading National Taxpayer Advocate – Pushes for Positive Changes for Americans Abroad →

Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess

In a holding by the US Tax Court on April 8, 2024, the case of Raju J. Mukhi v. Commissioner of Internal Revenue brought into sharp focus the principle of stare decisis and its implications for tax law. The Tax Court rejected the IRS’ assessment of penalties under Section 6038(b), for failure to file Form … Continue reading Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess →

Big Win for Taxpayers with Foreign Assets: IRS Lacks Authority to Assess & Collect Penalties for Failure to File Foreign Information Returns

The Internal Revenue Service (IRS) was sucker-punched by the Tax Court on April 3, 2023 in the case of Farhy v. Commissioner, 160 T.C. No. 6 (2023). In that case, the Tax Court held that the IRS does not have the authority to assess and collect penalties asserted under Internal Revenue Code Section 6038(b), in the … Continue reading Big Win for Taxpayers with Foreign Assets: IRS Lacks Authority to Assess & Collect Penalties for Failure to File Foreign Information Returns →