Since 1969, Internal Revenue Code (IRC) section 162(f) has disallowed an ordinary and necessary business deduction in computing taxable income for any civil or criminal…
Written Supervisory Approval of IRS Penalties
When Must It Be Given, and Who May Give It?
The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue…
IRS Form 3520, Penalties, and Whether to Make a Protective Filing
Information Reporting on Foreign Trusts and Gifts
Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is…