Reasonable Cause & IRS Penalty Abatement Reasonable Cause & the IRS Reasonable Cause & Abatement of IRS Penalties: When it comes to the IRS and penalties, there are (generally) two situations in which reasonable cause is primarily used. In the first scenario, a person may have already been issued an IRS Penalty, and they are seeking to abate the penalty by proving the mistake was reasonable. In the second scenario, a person realizes they are…
Taxpayers who pay more tax than is due have the right to sue for a refund after exhausting their administrative remedies, and they may file suit either in a district court or in the Court of Federal Claims, as the courts have concurrent jurisdiction. 28 U.S.C. § 1346(a)(1). In addition to recovering the excess tax, taxpayers are entitled to overpayment interest. I.R.C. § 6611(a). Normally, the tax and the interest travel together, but in some…
The Made-Whole Doctrine Does Not Apply To First-Dollar Risk in New Jersey A self-insured retention or deductible is an amount of risk that the insured has agreed to assume in exchange for a lower premium cost for the insurance policy. Where the award from a subrogation action against a third party is insufficient to reimburse both the insured’s self-insured retention and the carrier’s loss in excess of the self-insured retention, to place priority of recovery…

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