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Great News For Delinquent 2019 and 2020 Filers

Posted by Brian Ketcham | Sep 22, 2022 | 0 Comments

Earlier this month the IRS announced sweeping penalty relief for millions of taxpayers who filed their 2019 and/or 2020 tax returns late.  See IRS Notice 2022-36; IR-2022-155.  The relief is targeted at taxpayers who may have struggled in the wake of the Covid-19 pandemic, but it is not limited t...

Rare Taxpayer Win in SDNY Civil FBAR Case

Posted by Brian Ketcham | Mar 09, 2022 | 0 Comments

In an opinion filed yesterday in the Southern District of New York, U.S. District Judge Mary Kay Vyskocil denied a motion for summary judgment filed by the government that sought a ruling that a taxpayer's failure to file an FBAR was willful as a matter of law, rejecting the government's position...

Lingering OVDP Accounts

Posted by Brian Ketcham | Dec 10, 2021 | 0 Comments

As many tax controversy practitioners have learned since the advent of the first IRS Offshore Voluntary Disclosure Program (OVDP), some cases just won't die, even since the OVDP's sunset in 2018.  Some cases turned out to be very complex, other cases involved long tortuous procedures to obtain th...

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