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Expert Analysis

An Old 'New' Defense To IRS Penalties

By Rebecca Stork and Thomas Cullinan (June 1, 2018, 4:19 PM EDT) -- Until very recently, taxpayers had two primary lines of defense against civil tax penalties asserted by the Internal Revenue Service. First, the taxpayer could seek to show that one or more of the elements of the penalty were not met — e.g., the understatement of tax was not substantial or the underpayment was not attributable to negligence. Second, the taxpayer could argue it had reasonable cause for the underpayment and acted in good faith — e.g., the taxpayer relied on the advice of a qualified tax adviser. ...

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