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…
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…
Flume v. Commissioner (here) revolved around one noteworthy issue: did the taxpayer’s reliance on the advice of his tax return preparer spare the taxpayer from $110,000 in penalties for the taxpayer’s failure to report foreign investments on Form 5471? The taxpayer argued that he relied on the expertise of his tax return preparer to guide…
