:: Add To Favorites :: Set As Homepage

 

:: 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 Introduction Coverage Overview Focus Tax Shelters Tax Shelters continued Penalty Policy: Facts and Documentation to be Developed During the Examination LMSB SB/SE Managerial Approval of Penalties Accuracy-Related Penalty – IRC § 6662 In General IRC § 6662 - Accuracy-Related Penalty Penalty Amount Definition of Underpayment Negligence or Disregard of Rules or Regulations Negligence Disregard of Rules or Regulations Adequate Disclosure Substantial Understatement In General Definition of Tax Shelter for Purposes of IRC § 6662(d) Substantial Authority Exception  Substantial Valuation Misstatement In General Fraud Penalty – IRC § 6663 Introduction Reasonable Cause and Good Faith – IRC § 6664 Reasonable Cause & Good Faith Exception - In General  Taxpayer’s effort to assess the proper tax liability  Experience, Knowledge, Sophistication and Education of Taxpayer  Reliance on Advice  Reportable Transactions  Nontax Matters  Advisor Independence  Special Rules for Tax Shelter items of a Corporation  Announcement 2002-2  Introduction  “Issues Raised During An Examination”  Applicability of Announcement 2002-2  Policy Statements  IRS Commissioner Memorandum dated December 29, 2003  LMSB Commissioner Memorandum dated December 20, 2001  LMSB Commissioner Memorandum dated July 10, 2003  Audit Techniques – Development of Potential Penalty Issues for Tax Shelter Cases  Inquiries relating to accuracy-related penalty  Inquiries relating to Reasonable Cause & Good Faith  Inquiries Relating to Reliance on Advice

HOME  ::  FIRM PROFILE  ::  TAX HELP  ::  RESOURCES  ::  SITEMAP  ::  CONTACT US

Presented by Alvin Brown and Associates, tax attorney, formerly with the Office of the Chief Counsel of the IRS.
Call us for all IRS tax issues, problems and emergencies.
Protect yourself from IRS intimidation, errors, and penalties.
www.irstaxattorney.com - ab@irstaxattorney.com - (888) 712-7690 - (703) 425-1400

Web Design & Web Development by Web Design Company YottaDesign, LLC