On October 28, 2013 the IRS revised the Internal Revenue Manual (IRM) providing guidance and clarification regarding the administrative review of FBAR penalties by the IRS Office of Appeals. See http://www.irs.gov/irm/part8/irm_08-011-006.html
The IRM is essentially the operational manual providing guidance and procedures for the various functions carried out by the IRS.With respect to FBAR penalties being considered for resolution by IRS Appeals, the revised IRM 8.11.6 provisions reference 10 key points:
IRS FBAR Administrative File.
Limited Jurisdiction for Post-Assessed FBAR Penalties. Read More
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