Tax Shelters (Section 6707A)

Relief from Penalties Imposed by Section 6707A The Small Business Jobs Act of 2010 ("SBJA"), signed into law in September of last year provides enormous relief for those who would have suffered penalties from not disclosing certain tax shelters to the IRS. Internal Revenue Code section 6707A imposes strict penalties...

Audit Enforcement and Audit Plan Strategies

Audit Plan Strategies The Treasury Inspector General for Tax Administration (TIGTA) is responsible for monitoring and directing the IRS's activities.   Recently, the TIGTA estimated that taxpayers will owe $345 billion more than what they actually claim they owe on their income tax returns this year.  Because they are expecting this...

White Collar Crime, Structuring

Federal law requires business and financial institutions to report currency transactions in excess of $10,000 in a single or “related” transaction within a twelve-month period. Businesses must file an IRS form 8300 and financial institutions must file a currency transaction report. Even though making a deposit or withdrawal greater than...