If you have an account at one of the IRS “bad banks” and you used the Offshore Voluntary Disclosure Program (OVDP), you will face a 50 percent offshore penalty on the highest aggregate account balance during the disclosure period, instead of the regular 27.5 percent offshore penalty. On top of…
Appealing the results of an IRS examination is usually beneficial to a taxpayer if there is a basis for disputing the findings. The process doesn’t cost anything (although it’s highly recommended that you retain a tax audit attorney), and could potentially result in significant tax savings, making it a good…
It’s best to try to stop a wage garnishment before it happens. If you owe the IRS back taxes and do not have any arguments for why the tax assessment is improper or incorrect, you should consider entering into an installment agreement or negotiating an Offer in Compromise. This will…
You will need to get a tax litigation attorney’s opinion on whether or not you willfully failed to file Foreign Bank Account Reports (FBARs) and report foreign income on your tax return. The answer to this question has several consequences, including the following: Non-willful FBAR violations carry a $12,459 penalty…
Some types of tax debt can be discharged in a Chapter 7 bankruptcy, and a debtor may pay less than the full amount owed for some taxes in a Chapter 13 bankruptcy. The amount of tax relief that is available will depend on several factors including: The type of bankruptcy…
The blanket IRS tax lien automatically applies to all of your property whenever you owe taxes to the IRS. This lien does not result in immediate collection of your tax debt like a bank account seizure or wage garnishment, but it does encumber your property, making it difficult to sell…
If you were previously unaware of your obligation to file Foreign Bank Account Reports (FBARs), you have a strong argument that your conduct was non-willful, which could qualify you for reduced penalties under the Streamlined Filing Compliance Procedures. However, once you are aware of your obligations, you can no longer…
The general rule of the IRS is to audit returns that have been filed in the last three years. Because of this, some taxpayers may breathe a sigh of relief once the three-year period has expired, but the rules regarding the statute of limitations are not quite that simple. There…
Charged with administering, enforcing, and collecting taxes from millions of Americans, the IRS understandably makes mistakes. If the IRS is trying to charge you penalties or assess taxes incorrectly, or is attempting to seize your bank account or put a lien on your house, you have options for disputing the…
The former Vice President of a South Carolina-based bank has pleaded guilty to conspiring to defraud the United States by participating in an employment tax fraud scheme that resulted in over $1 million in unpaid payroll taxes. This case shows that the Department of Justice will go after those who…