The Lamprecht case is a good reminder of how long and complex the path can be for international taxpayers to correct prior wrongs and come into compliance for federal income tax purposes. On April 23, 2024, in Lamprecht v Commissioner, ___ F.4th ___ (D.C. Cir. 4/23/24), ( D.C. Circuit Court opinion) the U.S. Court of…
Tax Court Wife of Convicted White Collar Criminal Denied Innocent Spouse Relief Taxpayer-Wife sought relief from joint liability originating in part from Taxpayer-Husband’s embezzlement of funds from a church for which he was convicted of fraud, identity theft and tax evasion . The Tax Court upheld the IRS’s determination that Taxpayer-Wife was not eligible for…
Joe and Mary operate a closely held business that generates a net operating loss in 2005 and 2007. The net operating loss from 2005 and 2007 are carried forward and are used to offset business income on Joe and Mary’s 2015 tax return. Joe and Mary’s 2015 tax return is selected by the IRS for…
