The IRS is apparently so happy with the results of it’s offshore voluntary disclosure program that it has established a similar program in the area of worker classification. Michael Cohn of AccountingToday writes that the IRS has introduced a new voluntary compliance program Wednesday to convince employers to resolve their past issues with classifying employees [...]

The IRS assesses penalties against taxpayers for, among other things, the following: late filing of a tax return; late payment of tax; the negligent preparation of a tax return; the substantial underpayment of tax; and civil fraud. Penalties range from 5 percent per month in the case of late filing of a return to 75 [...]

National Taxpayer Advocate Nina Olson has issued her annual report on the most frequently litigated tax issues: Internal Revenue Code § 7803(c)(2)(B)(ii)(X) requires the National Taxpayer Advocate to identify the ten tax issues most often litigated in the federal courts, classified by the types of taxpayer affected. Through analysis of these issues, the National Taxpayer Advocate [...]

The IRS assesses penalties against taxpayers for, among other things, the following: late filing of a tax return; late payment of tax; the negigent preparation of a tax return; the substantial underpayment of tax; and civil fraud. Penalties range from 5 percent per month in the case of late filing of a return to 75 percent [...]

§6672 of the Internal Revenue Code imposes a 20% penalty on a taxpayer’s substantial understatement of income tax: (d) Substantial understatement of income tax (1) Substantial understatement (A) In general For purposes of this section, there is a substantial understatement of income tax for any taxable year if the amount of the understatement for the [...]

§6672 of the Internal Revenue Code imposes a 20% penalty for negligent underpayments of tax: (a) Imposition of penalty If this section applies to any portion of an underpayment of tax required to be shown on a return, there shall be added to the tax an amount equal to 20 percent of the portion of [...]

§6673 imposes a 75% penalty for underpayments of tax that are attributable to fraud: (a) Imposition of penalty If any part of any underpayment of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 75 percent of the portion of the [...]