First Time Penalty Abatement of Federal Income Tax Penalty

The IRS imposes penalties on various taxpayer deficiencies. Penalties may include failure to file tax returns, failure to pay tax, substantial underreporting of income and many other penalties. Penalties can be abated or waived by the IRS upon a showing of reasonable cause by the taxpayer. However, the IRS also has a First Time Penalty…

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Montana Property Taxpayers Cannot Readily Rely on the Courts to Overturn Tax Appeal Board Decisions (Part 2 of 2)

In a previous article, I began examining Peretti v. State of Montana, Department of Revenue, 373 P.3d 447, 2016 MT 105. The case involves a Montana property taxpayer who had challenged her property tax but received unfavorable rulings from both the County Tax Appeal Board (“CTAB”) and the Montana Tax Appeal Board (“MTAB”), the administrative…

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Montana Property Taxpayers Cannot Readily Rely on the Courts to Overturn Tax Appeal Board Decisions (Part 1 of 2)

When it comes to property taxes, Montana taxpayers who disagree with their property tax assessment must follow a statutorily prescribed appeal process.[1] Following a discretionary opportunity to meet with the Montana Department of Revenue in an informal review to see if the tax dispute can be resolved without a tax appeal, the taxpayer must first…

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Idaho Federal District Court Makes Short Work of “Tax Defier”

The Federal District Court for the District of Idaho has made it known that it will not gladly suffer “tax defiers.” In United States v. Howe, 2020 WL 565217 (Idaho Federal District Court), the United States Department of Justice filed suit against a taxpayer to reduce to judgment $350,000 in federal income tax debt and…

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U.S. News – Best Lawyers “Best Law Firms” 2021 edition

Crowley Fleck is pleased to announce that we have been regionally ranked in 41 practice areas in the U.S. News – Best Lawyers “Best Law Firms” 2021 edition.  Please see the complete list by using the link below. The U.S. News – Best Lawyers “Best Law Firms” rankings are based on a rigorous evaluation process…

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Most Western States Limit Lawsuits Against Tax Authorities for Abusive Tax Audits

Previous articles examined the case of Franchise Tax Board of California v. Hyatt, 136 S.Ct. 1277 (2016), wherein the Franchise Tax Board of California was held liable for an abusive tax audit, although the monetary damages were capped by statute at $50,000. I have also examined the ability of a Montana taxpayer to sue the…

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