Civil Tax Controversies

Innocent Spouse Relief: The IRS’ Role in Supporting Healthy Relationships
Listen Getting married is a big deal. Outside of the expensive and onerous process of actually having a wedding, the marriage itself carries a lot of weight. Married couples are legally linked, sharing personal profit and loss relatively equally, and this includes at tax time. For most couples, taxes are just another laborious task required to live …
Big Win for Taxpayers in A Watershed “Willful” FBAR Penalty Case
Listen I’m a little slow in getting around to this one, but back on September 20, 2017, the Eastern District of Pennsylvania released a taxpayer-friendly opinion regarding the “willfulness” standard in FBAR penalty cases. In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the district court held that the government had not met its burden of …