Omitted Income, Accuracy Related Penalty and Reasonable Cause

Omitted Income, Accuracy Related Penalty and Reasonable Cause

Russ Fox over at Taxable Talk says that the Tax Court upheld an accuracy related penalty against a taxpayer even though the deficiency arose because his tax preparer failed to report a 1099 on his tax return: Everyone is…

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11th Circuit Case: Tax Preparer Escapes IRS Death Penalty

11th Circuit Case: Tax Preparer Escapes IRS Death Penalty

I hope you’re paying attention Mr. Laskey. John Pacenti of Law.com reports: The 11th U.S. Circuit Court of Appeals, with retired U.S. Supreme Court Justice Sandra Day O’Connor writing for a three-judge panel, upheld a…

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IRS Substantial Understatement Penalty

IRS Substantial Understatement Penalty

§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,…

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Tax Court Update – January 2009 – Section 6673 “Delay” Penalty

Tax Court Update – January 2009 – Section 6673 “Delay” Penalty

John Charles Vuckovich v. Commissioner of Internal Revenue – Here the taxpayer sued the IRS for inappropriately filing a federal tax lien against him. The fact pattern is a familiar one: The taxpayer failed to file…

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