Most of my readers are aware of the “attorney-client privilege”. Generally speaking, the privilege preserves the confidentiality of communications between a lawyer and her clients. When the privilege is in place, attorneys may not divulge their clients’ secrets and cannot be "forced" to divulge them (for example, in a court proceeding or to the Internal … Continue reading Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!
For those of you who have been sleeping too much the past few days, let’s wake up and learn a bit about the face-off in Washington DC over the border security wall. Right now, there’s no federal budget in place and funding for many government agencies has disappeared, resulting in partial shutdowns for some, including … Continue reading SHUTDOWN… Last IRS Agent to Leave, Please Turn off the Lights
Another court just slammed the Internal Revenue Service (IRS), limiting the “willful” FBAR penalty to $100,000. Another taxpayer victory took place last week in United States v. Wadhan, (Civil Action No. 17-CV-1287-MSK District Court, District of Colorado July 18, 2018). The Wadhan’s failed to file or filed inaccurate so-called FBARs for 2008, 2009, and 2010. … Continue reading Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000
I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating that a taxpayer “willfully” failed to file an FBAR. The “burden of proof” refers to which party is responsible for putting forth evidence and, the level of evidence … Continue reading FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge”