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Rule 2341 Amendment of Pleadings View Document Form

Rule 2341 Amendment of Pleadings View Document Form

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often taxpayers complain the tax code is too complex however a recent court decision has the IRS complaining U.S taxpayers who are officers directors or shareholders of foreign corporations may be required to file form 5471 failing to file form 5471 triggers a significant tax penalty on the taxpayer that is until a recent Tax Court decision far he vs commissioner on April 3rd 2023 the tax Court ruled in Far hiverse commissioner that the form 5471 penalty provision located at section 6038 B of the Internal Revenue code didn't technically authorize the IRS to assess the penalty against taxpayers that is to formally record the penalty the penalty for failing to timely file this form is ten thousand dollars for each year but can go up to fifty thousand dollars per year if the IRS notifies you of your failure to file and you still failed to file the form so what's the impact of this court decision if the IRS is investigating whether you are subject to a penalty related to th

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