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Author: Parag Patel

Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties

6 April, 2023

Last week the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could not assess or collect penalties under Internal Revenue Code (Code) Section 6038(b) for a late-filed Form 5471 against Alon

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Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case

3 April, 2023

The US DOJ Tax Division recently conceded penalties assessed against a police officer for failing to file informational returns on for a foreign gift. Krzysztof Wrzesinski, a Polish-American citizen, had failed to file Form 3520,

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Rare Supreme Court Ruling Favors Taxpayers!

1 March, 2023

The US Supreme Court rarely hears tax cases, but this week ruled on a case in favor of taxpayers. The case was originally heard because lower courts issued conflicting opinions. This week, the Supreme Court

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Demystifying IRS Agents

18 February, 2023

The IRS is planning to hire thousands of new agents in the next few years.  Some politicians and the media have portrayed the new hires as a harassing threats to taxpayers. In my decades of

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New Rules: New Jersey Finally Follow Federal S Elections

16 February, 2023

On December 22, 2022, New Jersey Governor Murphy signed into law a new rule that eliminates the need to make separate New Jersey S elections. The law primarily conforms New Jersey’s laws regarding the making of

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Top 5 tax fraud recoveries in 2022

11 February, 2023

Tax fraud can take many different forms. Below are the top federal tax fraud cases last year. Crypto Seizures: more than $7 billion. In February, 2022, it was announced that IRS Criminal Investigations Cyber Crime Unit

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Sales Tax for Home Improvements

5 February, 2023

Since New Jersey sales tax rules differ based on the type of work performed, it is important to understand the classifications to avoid paying too much or too little in taxes. What work is exempt

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New FATCA / CRS reporting penalties in India

3 February, 2023

The new 2023 Tax Budget in India has many new proposals. However, the most important proposal for investors, especially non-resident Indians, is a new penalty for providing inaccurate information for KYC (Know Your Customer) including

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65 Day Election on March 6, 2023

21 January, 2023

Trustees and executors have the ability to make certain elections on, or before, March 6, 2023 that could affect 2022 tax returns of the trusts and estates for which they are fiduciaries, as well as

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High Penalties for failure to file an FBAR: Not Really Enforced (yet)?

19 January, 2023

U.S. persons, including U.S. citizens, residents, corporations and estates, must report certain foreign financial accounts, including bank accounts, brokerage accounts and saving accounts to the U.S. Treasury department each year. If the aggregate value of

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IRS Audits of Millionaires Remain Very Low

15 January, 2023

The Internal Revenue Service still rarely audits millionaires, according to a new report published by Syracuse University’s Transactional Records Access Clearinghouse. Despite calls to ramp up scrutiny of high-net-worth individuals’ tax returns and wealthy tax

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IRS Listens, and Postpones Increased Form 1099 Reporting for PayPal and Venmo

30 December, 2022

As a result of taxpayer confusion, lack of guidance, concerns about the existing backlog, and impact on the upcoming filing season, tax professionals urged the IRS to postpone the implementation of the new reporting requirements

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Recent Posts

  • The Push to Eliminate Duplicative FBAR and Form 8938 ReportingFebruary 4, 2026
  • Unfortunate Tax Lessons from the Dr. Merchia Fraud ConvictionFebruary 3, 2026
  • The High Cost of Cash: Analyzing the $3 Million Tax Evasion Sentencing of a ContractorFebruary 2, 2026
  • Is Turbotax Reliance a Valid Defense Against IRS Penalties?January 28, 2026
  • New Proposed IRS Voluntary Disclosure Practice (VDP): FAQsJanuary 20, 2026

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