An investment in knowledge pays the best interest.
The American Taxpayer Relief Act provides the surviving spouse the opportunity to “port” the unused amount of the deceased spouse’s estate tax exemption (“DSUE”). To utilize this DSUE, a timely estate tax return (Form 706) needs to be filed, even if one is not otherwise needed.
In U.S. v. Collins, the Federal District Court in the Western District of Pennsylvania decided on February 8, 2021, to uphold a FBAR Civil Willful Penalty.
The Court found that the taxpayer was sophisticated in financial matters “well beyond that of an average person,” and knew of his foreign accounts. More critically, the Court held that the taxpayer identified an interest in keeping the foreign accounts secret, consciously avoided disclosing the accounts, and that there was an actual intent to deceive the IRS. The Court noted that the taxpayer
New York continues to aggressively argue that taxpayers are New York residents. In the recent Tax Appeals Tribunal Case of Obus and Coulson the Tribunal affirmed the deficiency against the taxpayers. The State argued they were “statutory residents” even though the taxpayers maintained that they lived in New Jersey and were only required to file New York income tax returns as non-residents.
As of November 2, 2020, patients now have additional rights to their medical files under the full implementation of the 21st Century Cures Act, the last legislation signed by the Obama administration which coincidentally included the provision giving individuals the right to create their own SNT.
Michael A. Lampert Named 2020-2021 Gerald T. Hart Outstanding Tax Attorney of the Year
The Florida Bar Tax Section will honor Michael A. Lampert with the 2020-2021 Gerald T. Hart Outstanding Tax Attorney of the Year Award.
The section chair each year selects a recipient to recognize his or her contributions to the
The U.S. Treasury houses “TIGTA” - the Treasury Inspector General for Tax Administration. TIGTA, being outside of the IRS, acts somewhat as an “Internal Affairs” for the IRS. It also works hard to maintain the integrity of the tax system. TIGTA has both law enforcement and general audit/review functions. They regularly review aspects of how the IRS operates.