Tag Archives: CIVIL FRAUD PENALTY

WHAT CONDUCT WILL TRIGGER THE 75% CIVIL FRAUD PENALTY OF IRC SECTION 6663?

 In Ward v. Commissioner, T.C. Memo. 2013-133 (May 29, 2013), Mr. Ward sought redetermination of an IRS proposed deficiency on a number of grounds. This post addresses only his disputation of the civil fraud penalty proposed.  Judge Kerrigan’s decision contains … Continue reading

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