Henry Stow Lovejoy Archives - Kostelanetz & Fink, LLP

Stow Lovejoy Participated In A Webinar Entitled “Mastering Form 5472: Filing Requirements For Foreign Individuals, Llcs, And Companies” For Strafford On July 23, 2020

This webinar provided tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact of IRS regulations requiring 5472 reporting by foreign owners of disregarded entities (DREs). The panel provided line-by-line guidance on completing the form, define difficult concepts, and discuss the impact of IRS

Written Supervisory Approval Of IRS Penalties: When Must It Be Given, And Who May Give It?

By Henry Stow Lovejoy CPA Journal April 2018 Edition The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior.Generally, the revenue agent examining a return will be one who proposes a penalty. Revenue agents are instructed to consider penalties

Choice Of Forum Matters: Tax Court And District Court Reach Different Conclusions On Same Facts Regarding Penalties

By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in advance can sue for refund

When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining

Reasonable Cause For International Information Return Penalties – What Is The Standard?

By Henry Stow Lovejoy Original Publication: The CPA Journal, April 2017 Edition Re-Published & Updated Publication: The Practical Tax Lawyer, Summer 2017 Edition The Internal Revenue Code (IRC) requires the filing of a number of different information returns with respect to foreign entities or transactions. These “international information returns” include Form 5471 (for

Tag: Henry Stow Lovejoy

Stow Lovejoy Participated In A Webinar Entitled “Mastering Form 5472: Filing Requirements For Foreign Individuals, Llcs, And Companies” For Strafford On July 23, 2020

Written Supervisory Approval Of IRS Penalties: When Must It Be Given, And Who May Give It?

Choice Of Forum Matters: Tax Court And District Court Reach Different Conclusions On Same Facts Regarding Penalties

When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

Reasonable Cause For International Information Return Penalties – What Is The Standard?

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