The Parameters of Qualified Amended Returns Examined by Tax Court in Case of First Impression

By Hale Sheppard Life grants few chances at true redemption. The Internal Revenue Code, likewise, is not known for facilitating taxpayer salvation. Sure, under certain circumstances, taxpayers have an opportunity to file late tax-related elections to rectify an oversight, and other forms of clemency exist. However, the general rule is that taxpayers are stuck with … Continue reading The Parameters of Qualified Amended Returns Examined by Tax Court in Case of First Impression

Always Say Never: Does Financial Distress Create Reasonable Cause Sufficient To Abate Tax Penalties?

By Hale Sheppard Nearly all taxpayers will face penalties by the IRS at some point, regardless of their sophistication level and size.  Accordingly, tax practitioners, even those who claim not to get involved in traditional "collection" activities, must understand key aspects of abatement and collection procedures in order to effectively advise their clients.  This is … Continue reading Always Say Never: Does Financial Distress Create Reasonable Cause Sufficient To Abate Tax Penalties?

The Romneys’ Tax Returns: Have FBARs Been Filed, Or Is Romney An OVDI “Candidate”?

By Jonathan Prokup and Dustin Covello Following the release of Ann and Mitt Romney’s tax returns, the news media and political commentators of all stripes have – to paraphrase Arlo Guthrie – detected, neglected, selected, rejected, and inspected those returns for a variety of commercial and political purposes.  As expected, the return shows substantial income, … Continue reading The Romneys’ Tax Returns: Have FBARs Been Filed, Or Is Romney An OVDI “Candidate”?