Topic
Reasonable Cause
10 published works
Rubin On Tax
The TurboTax Defense: A New Chapter
The TurboTax Defense to federal tax penalties—where taxpayers cite reliance on tax software like TurboTax to avoid penalties—has historically been a tough sell. However, Huang v. United States (N.D. Cal.…
Milikowsky Tax Law Blog
How to Abate an IRS Penalty
There are a lot of different types of penalties IRS can assess. Let’s start with the failure to file. Typically, it’s a firm deadline and when you have to file…
Dollars & Sense
Asking the IRS to Abate Penalties
By Joshua Smeltzer, Admin
All kinds of penalties are being assessed by the Internal Revenue Service (IRS) against taxpayers, and more can be expected in the future. In 1954 there were 13 penalties in…
Tax
Protective Reasonable Cause Letter to Avoid Tax Penalties
By Board-Certified Tax Law Specialist
Protective Reasonable Cause Letter to Avoid IRS Penalties Protective Reasonable Cause Statement to Avoid IRS Penalties Protective Reasonable Cause Letter to Avoid IRS Penalties: When it comes to International Information…
Tax
District Court Limits Annual FBAR Penalty Per Form: (New) 2021
Court Rules Penalty for Non-Willful FBAR is Per Form: New 2021 Per Form FBAR Penalty for Non-Willful Per Form FBAR Penalty for Non-Willful: In United States v. Zvi Kaufman No.…
Tax
Reasonable Cause to Challenge IRS Tax Penalties
Reasonable Cause & IRS Tax Penalties Reasonable Cause & IRS Tax Penalties Reasonable Cause & IRS Tax Penalties: When a non-willful taxpayer faces potential penalties for failing to comply with…
Tax
Reasonable Cause & IRS Penalty Abatement
By Board-Certified Tax Law Specialist
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…
Tax
Reasonable Cause vs Streamlined: What’s the Difference?
By Board-Certified Tax Law Specialist
Reasonable Cause vs Streamlined-What’s the Difference? Reasonable Cause vs Streamlined: The Reasonable Cause vs Streamlined Filing IRS Submission analysis is very complicated. The Streamlined Procedure (Domestic or Foreign) is an…
Rubin On Tax
Late Filing Penalties Apply When Accountant Erroneously Fails to Hit “Send”
Taxpayers who file a return late are subject to penalty under Code §6651 “unless it is shown that such failure is due to reasonable cause and not due to willful…
In Solvency
Yes. It is Possible to Avoid Tax Penalty Claims in Bankruptcy
By Fox Rothschild LLP, Fox Rothschild LLP
On August 2, 2016, Judge Brendan L. Shannon of the Delaware Bankruptcy Court issued an opinion (the "Opinion") in the Refco Public Commodity Pool, L.P. bankruptcy, Case No. 14-11216. A…