Does Reliance on an Insider Provide Penalty Protection
7 Pages Posted: 22 Oct 2011 Last revised: 24 Oct 2011
Date Written: October 21, 2011
Abstract
Penalties are always important in tax practice, but they are particular prominent now. For example, (i) penalties are central to the government's current campaign against tax shelters, (ii) the National Taxpayer Advocate has identified excessive assertion of the Code Sec. 6662 accuracy-related penalty in the IRS's Automated Underreporter Program as one of the most serious problems encountered by taxpayers and (iii) the Taxpayer Advocate intends to recommend that the joint Committee on Taxation review the Internal Revenue Code's penalty structure with the goal of "bringing sanity back."
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