Tag Archives: TAX PENALTIES

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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IRS FIRST TIME ABATE POLICY PROVIDES PENALTY RELIEF IN CERTAIN SITUATIONS

The IRS today clarified its policy with regard to abatement of certain penalties for first time offenders.  The policy was modified to clarify that relief applies only where the taxpayer is current with all tax filings and tax payments. See IRM … Continue reading

Posted in COMPLIANCE, DELINQUENT RETURN, EMPLOYMENT TAXES, IRS COLLECTIONS, POLICY, RETURNS, TAX, TRUST FUND PENALTY, UNFILED RETURNS | Tagged , , , , , , , | 6 Comments