Failure to File International Information Forms Allows IRS to Assess Taxpayer More Than Five Years Past Normal Statute of Limitations
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Failure to File International Information Forms Allows IRS to Assess Taxpayer More Than Five Years Past Normal Statute of Limitations

ByJustin Hughes - JD, CPA, LLM

The Fairbank case demonstrates the power of IRC § 6501(c)(8) to provide the IRS the ability to assess taxpayers many years after the normal statute of limitations is closed if the taxpayer fails to file all required IRS international information reporting forms. In Fairbank v Commissioner, T.C. Memo. 2023-19, the IRS argued that, despite the…

Taxpayer Wins District Court Case on Calculation of Non-Willful FBAR Penalties

ByJustin Hughes - JD, CPA, LLM

In U.S. v. Bittner [1](available here: link), the U.S. District Court for the Eastern District of Texas (the “Court”) handed taxpayers a victory by declining to follow the legal analysis in Boyd v U.S.   In doing so the Court rejected the IRS’s interpretation of what constitutes a “violation” for purposes of computing non-willful FBAR penalties…