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Reasonable Cause Defense Tax Penalties

Freeman Law

Tax Court in Brief | Mulu v. Comm'r | Accuracy-Related Penalty and No Reasonable-Cause Excuse

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Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses whether or not to uphold an accuracy-related penalty assessed to taxpayer, Ashenafi Getachew Mulu (Mulu). Mulu hired David...more

Freeman Law

How to Successfully Fight the Section 6721(e) Intentional Disregard Penalty

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Section 6721 provides the IRS with authority to impose civil penalties against taxpayer-employers who fail to timely file correct information returns (e.g., Forms W-2/W-3 and Forms 940/941). Under section 6721’s three-tiered...more

Freeman Law

IRS Tax Penalties and the Tax Professional Reliance Defense

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IRS Tax Penalties and the Tax Professional Reliance Defense - No one wants to pay federal taxes. And this truism applies more so with respect to federal tax penalties. Accordingly, clients often call upon their tax...more

Freeman Law

Reasonable Cause: An Estate’s Defense Against IRS’s Late-Filing Penalties

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The Internal Revenue Code (the “Code”) contains over 150 civil tax penalties for various conduct and non-conduct. One common group of penalties, associated with the late filing of a tax return and the late payment of tax,...more

Freeman Law

Clarifying the Contours of “Reasonable Compensation”

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The law has always favored the term “reasonable.”  For example, the law affords protection against a negligence lawsuit if a person can demonstrate he or she acted as a reasonable person would have under similar...more

McDermott Will & Emery

Reasonable Cause for E-Filing Errors?

Tax return filing season is fast approaching, and taxpayers big and small are preparing to file their returns. A recent US Court of Appeals for the Fifth Circuit decision, Haynes v. United States, No. 17-50816 (5th Cir. Jan....more

Burr & Forman

South Carolina Tax Penalties

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South Carolina imposes a number of civil tax penalties that are similar to those imposed under the Internal Revenue Code (the “Code”). South Carolina’s civil tax penalties, while similar in some respects, are not the same as...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The Case Against Do-It-Yourself Tax Returns: You Don't Know What You Don't Know

In an effort to comply with the increasing complexity of the Internal Revenue Code (the “Code”) and the regulations promulgated thereunder, many taxpayers are looking to tax preparation software for assistance in preparing...more

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