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Accuracy - Audit Techniques Guide |
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Audit Techniques Guide
Accuracy
- Related Penalties For Taxpayers Involved In Tax Shelter Transactions Accuracy-Related
Penalties for Taxpayers Involved In Tax Shelter Transactions - Table of
Contents Publication
Date - August, 2004 NOTE:
This guide is current through the publication date. Since changes may
have occurred after the publication date that would affect the accuracy
of this document, no guarantees are made concerning the technical
accuracy after the publication date. This Audit Techniques Guide (ATG) is presented in several chapters. These chapters can be accessed and then printed by following the links in the Table of Contents below. To print the entire ATG please refer to the PDF version. Table
of Contents 1.
Introduction o
Coverage o
Overview o
Focus o
Tax Shelters o
Tax Shelters continued o
Penalty Policy: Facts and
Documentation to be Developed During the Examination o
LMSB o
SB/SE o
Managerial Approval of
Penalties 2.
Accuracy-Related
Penalty – IRC § 6662 o
In General o
IRC § 6662 - Accuracy-Related
Penalty o
Penalty Amount o
Definition of Underpayment 3.
Negligence
or Disregard of Rules or Regulations o
Negligence o
Disregard of Rules or
Regulations o
Adequate Disclosure o
In General o
Definition of Tax Shelter for
Purposes of IRC § 6662(d) o
Substantial Authority Exception 5.
Substantial
Valuation Misstatement o
In General o
Introduction 7.
Reasonable
Cause and Good Faith – IRC § 6664 o
Reasonable Cause & Good
Faith Exception - In General o
Taxpayer’s effort to assess
the proper tax liability o
Experience, Knowledge,
Sophistication and Education of Taxpayer o
Reliance on Advice o
Reportable Transactions o
Nontax Matters o
Advisor o
Special Rules for Tax Shelter
items of a Corporation o
Introduction o
“Issues Raised During An
Examination” o
Applicability of Announcement
2002-2 o
IRS Commissioner Memorandum
dated December 29, 2003 o
LMSB Commissioner Memorandum
dated December 20, 2001 o
LMSB Commissioner Memorandum
dated July 10, 2003 10.
Audit
Techniques – Development of Potential Penalty Issues for Tax Shelter
Cases o
Inquiries relating to
accuracy-related penalty o
Inquiries relating to
Reasonable Cause & Good Faith o
Inquiries Relating to Reliance
on Advice |
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