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IRS Shortening Taxpayer Response Times in Audits?

By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Friday, June 19, 2015. A recent report out of South Dakota asserted that the IRS has shortened the amount of time it allows US taxpayers for responding to requests from the IRS during an audit.  The...

Judge Agrees to Hearing in IRS verus Microsoft Case

By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Thursday, June 18, 2015. Microsoft has challenged the IRS' authority to bring in a private, outside attorney to advise the agency on their deep and complex audit of Microsoft.  The central question involves the ability of...

Many Swiss Banks are an Automatic 50% FBAR Penalty

By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Monday, June 15, 2015. The IRS has generated a list of banks, many of whom are Swiss, who have participated in actively helping US taxpayers to shelter money and income from the IRS.  If you have...

IRS Updates FBAR Penalty Guidelines and Willful Conduct Parameters

By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 10, 2015. There has been a lot of confusion over what will constitute "willful" versus "non-willful" conduct in terms of FBAR reporting of foreign bank acounts and associated penalties for under-reporting them.  The IRS...

Appeals court undercuts California regulator in tax dispute

On behalf of Janathan L. Allen, APC posted in Tax Controversy on Friday, June 5, 2015. Part of California's tax policy has been ruled unconstitutional. The decision is being seen by some as a win for out-of-state businesses and, more specifically, individuals who might be interested in buying Harley-Davidson motorcycles...