What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...
How to Prepare for an IRS Audit
We are often asked how to prepare for an IRS audit. If you have received a letter of notification from the IRS concerning an audit, the first step you should take is to download our free guide "What to Expect from an IRS Audit" and contact the experienced tax attorneys...
The Statute of Limitations for an IRS Audit
What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of their minds while filing their taxes, perhaps...
What to do if You Receive an IRS Audit Notification Letter
What should you do if you receive an IRS audit notification letter? Why should you consider engaging experienced IRS audit and tax attorney Janathan Allen, who represents U.S. taxpayers facing an IRS audit or any other federal or state tax issue. There are several things you should know if you...
You Sign Every Tax Return Under The Penalties of Perjury
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that they had examined the return and underlying schedules. The "Sign Here" block...
An IRS Audit Doesn’t Have to Be a Nightmare
An IRS audit doesn't have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood of the best possible outcome in an IRS...
US Treasury Says IRS is Focused on Tax Evasion Targeting
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has deployed Artificial Intelligence (AI) and state-of-the-art computer systems to review the often-complex returns of large corporations,...
Willful versus Non-Willful Conduct in the Eyes of the IRS
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how seriously the IRS takes “willful” conduct into account as it applies to an audit or tax-related investigation. ...
Are There Strategies to Avoid an IRS Audit?
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to amend a previous return or come into compliance...