Don't Forget To Challenge IRS Interest Assessments

Law360, New York (April 28, 2014, 1:49 PM EDT) -- While the focus in most tax cases is on tax and penalties, statutory interest on any tax deficiency or penalty should not be overlooked. Interest on tax deficiencies and penalties is imposed automatically and, in many instances, can equal or exceed the tax and penalty liabilities.

It is, therefore, critical that taxpayers and their representatives carefully review IRS interest computations. Even where the technical computations themselves are accurate, the IRS still may be overcharging interest. Internal Revenue Code Section 6404 includes two important provisions that offer the potential for substantial interest reductions.

IRC Section 6404(g) provides, for IRS notices issued after...

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