Representations & Examinations
In a study, the US Government Accountability Office finds that the Internal Revenue Service’s individual tax audit rates decreased by 72% during 2010–2019, and by a greater percentage for higher-income taxpayers than for lower-income ones.
The immediate supervisor who must approve IRS penalties is the person who directly supervises the work of the examining agent in an examination.
A whistleblower is not entitled to an award where information provided did not directly result in the tax collected by the IRS.
Changes significantly affect how an innocent spouse
case is prepared and places an increased burden on return preparers who interact with a taxpayer who potentially has an innocent spouse claim.
Tax practitioners can rely on several doctrines
to preserve the confidentiality of client communications, but they must follow appropriate
procedures and provide clear documentation to protect the privilege in IRS exams or legal proceedings.
Proposed regulations provide that the IRS may determine that the centralized partnership audit regime does not apply to adjustments to partnership-related items under certain conditions.
The IRS’s LB&I Division requested comments regarding the potential obsolescence of Rev. Proc. 94-69, under which certain large corporations may
be treated as filing “qualified amended returns” after the commencement of an IRS examination.
The IRS issued rules on two special enforcement matters for purposes of the unified partnership audit rules.
One of the biggest, yet most misunderstood, penalty defenses is that a tax position was based on reasonable cause and the taxpayer acted in good faith.
The IRS said it would once again begin charging fees to issue preparer tax identification numbers to return preparers for 2021.
The IRS has proposed to lower the fee it charges for preparer tax identification numbers (PTINs) when PTIN fees are reinstated.
The IRS launches fresh efforts to promote awareness of data security issues.
The TCJA and the PATH Act expanded the penalties on tax return preparers who fail to follow due-diligence procedures when clients claim certain credits or head-of-household filing status.
The IRS has authority to charge a user fee for preparer tax identification numbers, a federal appeals court held, paving the way for the agency to reinstate the charges for obtaining and renewing a PTIN.
The IRS has authority to charge a fee for obtaining or renewing preparer tax identification numbers.
The IRS has authority to charge a user fee for preparer tax identification numbers (PTINs) a federal appeals court held, paving the way for the agency to reinstate the charges for obtaining and renewing a PTIN.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
Practitioners should be aware of changes to the due-diligence requirements for returns that claim the earned income tax credit, the American opportunity tax credit, and/or the child tax credit.
Keeping a “scorecard” of the weight of authorities on a particular position can be helpful to determine the objective merits of a tax position.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
