IRS Collections, Liens & Levies

TOPICS / PROCEDURE

September 1, 2008

An Analysis of the New Preparer Penalty Proposed Regulations

This article analyzes the proposed regulations on the new Sec. 6694 preparer penalty provisions that were enacted as part of the Small Business and Work Opportunity Tax Act of 2007.

August 1, 2008

Proposed Preparer Penalty Regs. Released

Proposed regulations implement changes to the return preparer penalties in Secs. 6694 and 6695 and related provisions.

July 1, 2008

IRS Provides Guidance on Return Preparer Penalties

The IRS has provided guidance (Notice 2008-46) on the implementation of the return preparer penalties under Sec. 6694.

May 1, 2008

Sec. 6694 Tax Return Reporting Standards for Preparers

The Sec. 6694 tax return reporting standards applicable to tax return preparers were increased to “more likely than not” for undisclosed nontax-shelter items.

April 1, 2008

New Rules for Disclosure and Use of Tax Return Information by Tax Return Preparers

Newly finalized regulations should prompt all return preparers to evaluate their processes to ensure that they conform to the disclosure requirements of Sec. 7216.

April 1, 2008

Partnership Returns: Late Filing Penalties Increase

Late 2007 legislation brought changes to Sec. 6698, which provides for penalties against a partnership for filing a late or incomplete return.

March 1, 2008

IRS Issues Rules on New Preparer Penalties

Notice 2008-13 implements the expanded tax return preparer penalties and increased standards of return preparer conduct enacted by the Small Business and Work Opportunity Tax Act of 2007.

March 1, 2008

The Ongoing Sec. 67(e) Controversy and the New Preparer Penalties

This item discusses how the 2% floor affects a trust’s regular tax and alternative minimum tax (AMT), the effect of the recent Supreme Court decision in Knight on the continuing controversy, and the efficacy of the proposed regulations in the wake of the Knight decision.

December 1, 2007

Practical Considerations for the New Paid Preparer Penalty Rules and FIN 48

Editor: Michael D. Koppel, CPA, PFS Return preparers have recently become subject to new, higher standards from two sources: Congress and the Financial Accounting Standards Board (FASB). This item compares the new “more likely than not” standard and explores the pitfalls that CPAs may encounter under FIN 48 and the

September 1, 2007

Scope and Size of Tax Preparer Penalties Increase

Editor: Frank J. O’Connell, Jr., CPA, Esq. The Small Business and Work Opportunity Tax Act of 2007, enacted in May, increases penalties on preparers and raises the standard of nondisclosure positions from “realistic possibility of success” to “more likely than not.” The legislation also extends the reach of these penalties

August 1, 2007

Preparer Penalties

The Small Business and Work Opportunity Act of 2007 (SBWOA ’07) was enacted on May 25, 2007. (It was passed as part of the package that extended funding for the war in Iraq.) SBWOA ’07 changes the rules for imposing a return preparer penalty and increases the penalty amount. Under

July 1, 2007

Some Schedule K-1 Recipients Get Reportable Transaction Disclosure Relief

Editor: John L. Miller, CPA Taxpayers that discover after filing their returns that they indirectly participated in a reportable transaction through a passthrough entity may be able to rely on Prop. Regs. Sec. 1.6011-4(e)(1) to avoid reportable transaction penalties. The preamble to the proposed regulations (REG-103038-05, 11/2/06) provided that this