Section 6751(b) and Assessable - Penalties Section 6751(b) of the Code has been a potent weapon for taxpayers since the Second Circuit held in Chai that certain penalties are not valid without written managerial approval. ...more
Taxpayers are always interested in whether certain expenditures qualify as tax deductions. But many taxpayers often forget that expenditures may alternatively qualify for various tax credits. And all things being equal,...more
Also Referred to as Internal Revenue Code Section 6672; I.R.C. § 6672; Section 6672; Trust Fund Recovery Penalty -
Background. In certain instances, the Internal Revenue Code (the “Code”) requires persons to withhold...more
Federal tax law permits taxpayers to deduct so-called “theft losses,” provided certain requirements are met. Initially, a taxpayer must show that he or she will not receive compensation through insurance or another third...more
Tax professionals are intimately familiar with certain reporting requirements under the Internal Revenue Code. Indeed, a failure to properly and timely report a position on a return where it is otherwise required may result...more