412i and 419e plans litigation. IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Looking for the IRS Number? Call (800)829-1040.
IRS’s Current Position on Assessing Code Section 6707A Penalties
How the IRS is taking a “formalistic approach” in interpreting its own section 6011 regulations on disclosing reportable transactions and not following its own rules on which tax years to assess the Section 6707A penalty.
March 19, 2012 by Janice Eiseman, JD, LLM
The IRS has again commenced assessing penalties under Code Section 6707A, the penalty provision applicable to failure to disclose Congress-enacted reportable transactions in 2004. Congress amended Section 6707A in 2010 to help alleviate its draconian consequences. Under newly amended Section 6707A, applicable to all penalties assessed after December 31, 2006, the penalty, subject to certain maximum and minimum amounts, is equal to 75% of the decrease in reported tax as a result of the reportable transaction. How the IRS is applying the Section 6707A penalty can be described as “troubling.” The following case shows how troubling the IRS position is.
IRS’s Current Position on Assessing Code Section 6707A Penalties
ReplyDeleteHow the IRS is taking a “formalistic approach” in interpreting its own section 6011 regulations on disclosing reportable transactions and not following its own rules on which tax years to assess the Section 6707A penalty.
March 19, 2012
by Janice Eiseman, JD, LLM
The IRS has again commenced assessing penalties under Code Section 6707A, the penalty provision applicable to failure to disclose Congress-enacted reportable transactions in 2004. Congress amended Section 6707A in 2010 to help alleviate its draconian consequences. Under newly amended Section 6707A, applicable to all penalties assessed after December 31, 2006, the penalty, subject to certain maximum and minimum amounts, is equal to 75% of the decrease in reported tax as a result of the reportable transaction. How the IRS is applying the Section 6707A penalty can be described as “troubling.” The following case shows how troubling the IRS position is.