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Tax Audits Penalties Internal Revenue Code (IRC)

Offit Kurman

Top Audit Red Flags Businesses Shouldn’t Ignore

Offit Kurman on

My recent blog, So, The IRS Has Selected Your Return for Audit, discussed the four types of IRS audits. What factors may trigger an audit of a business’s income tax return?...more

FBT Gibbons LLP

Avoiding IRS Accuracy Penalties for a Substantial Underpayment of Tax

FBT Gibbons LLP on

There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more

Offit Kurman

USPS Postmark Changes Could Impact Tax Filing Deadlines

Offit Kurman on

A couple of years ago, I wrote a blog about the importance of sending any correspondence to the Internal Revenue Service via Registered or Certified Mail or by an approved overnight courier, rather than relying solely on the...more

Vinson & Elkins LLP

Whose Fraud Is It Anyway? The Expanding Reach of the Fraud Exception to the Statute of Limitations on Tax Assessment

Vinson & Elkins LLP on

Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more

White & Case LLP

Courts and Congress Say IRS Must Approve Civil Tax Penalties in Writing Before They Are Asserted

White & Case LLP on

For the last decade, the IRS has proactively asserted discretionary civil tax penalties that can be as high as 40 percent of the proposed tax liability. Oftentimes, the IRS has used penalties as bargaining chips to get...more

Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

Vinson & Elkins LLP on

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

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