Using IRS Supervisory Approval Rules To Fight Tax Penalties

By Andrew Roberson, Kevin Spencer and Denise Mudigere (February 20, 2020, 4:49 PM EST) -- Each year, the Internal Revenue Service proposes millions of dollars in penalties against taxpayers. Knowing how to defend against proposed penalties is essential for taxpayers and their advisers, and they will fare better when they understand the tools in their penalty defense toolbox.[1]

The tool discussed in this article relates to the penalty approval provisions in Internal Revenue Code Section 6751.[2] This tool has proved to be helpful for many taxpayers to avoid penalties in instances where the IRS has failed to comply with procedural obligations imposed by Congress to combat the proposal of penalties as a bargaining chip.

The Penalty...

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