Leslie Book has made available for download his article, “Tax Court To Consider IRS Procedure For Imposing Information Reporting Penalties,” published on Procedurally Taxing blog. The article beings as follows:
In Information Return Penalty Assessment Fight Coming to a Head [$] Andrew Velarde highlights a major tax procedure issue before the Tax Court. It concerns allegedly improper IRS procedures with respect to the assessment of penalties associated with the delinquent or erroneous filing of information returns. As Velarde notes, in Farhy v Commissioner, the IRS assessed significant penalties under Section 6038 stemming from the taxpayer’s failure to File 5471 “Information Return of U.S. Persons With Respect to Certain Foreign Corporations,” for his Belize foreign corporations. The stakes of the case are high, with the potential for upending the IRS’s longstanding practice for imposing civil penalties for the failure to file certain information based returns.
To see the full article, click here: “Tax Court To Consider IRS Procedure For Imposing Information Reporting Penalties”
Posted by Melissa Zheng, Associate Editor, Wealth Strategies Journal.