Taxpayers Should Prepare For The Next Penalty Battleground

By Andrew Roberson, Kevin Spencer and Evan Walters (May 21, 2019, 12:30 PM EDT) -- During a tax audit, taxpayers and the Internal Revenue Service often disagree on the tax treatment of one or more items reported on a tax return. Similarly, they may disagree on whether claims for credits or refund are correct. Most disagreements are resolved by the parties, but resolution is more difficult when penalties are on the table. This article focuses on the Internal Revenue Code Section 6676 penalty for disallowed refund claims, which the IRS is starting to assert more frequently.


Penalties can take many forms, the most common of which is the so-called "accuracy-related" penalty under IRC Section 6662.[1] This...

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