Abuse of Discretion

McNamee v. Commissioner (T.C. Memo. 2020-37)

On March 18, 2020, the Tax Court issued a Memorandum Opinion in the case of McNamee v. Commissioner (T.C. Memo. 2020-37). The issue presented in McNamee was whether the petitioner was liable for 17 preparer penalties or whether the penalties had been assessed improperly for want of a final administrative determination.

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Adequate Disclosure

A Comprehensive Guide to Preparer Penalties

Preparer penalties are like poison ivy. They lurk around every corner, and despite your best efforts, even the slightest step off the path of (tax return) righteousness can lead to a wholly uncomfortable time.  This article provides a comprehensive, step-by-step analysis of each of the preparer penalties under the Code, both civil and, yes, even criminal and examines, where possible, how to avoid them (after the fact – sort of like an administrative calamine lotion).

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McNamee v. Commissioner (T.C. Memo. 2020-37)

On March 18, 2020, the Tax Court issued a Memorandum Opinion in the case of McNamee v. Commissioner (T.C. Memo. 2020-37). The issue presented in McNamee was whether the petitioner was liable for 17 preparer penalties or whether the penalties had been assessed improperly for want of a final administrative

Read More »

A Comprehensive Guide to Preparer Penalties

Preparer penalties are like poison ivy. They lurk around every corner, and despite your best efforts, even the slightest step off the path of (tax return) righteousness can lead to a wholly uncomfortable time.  This article provides a comprehensive, step-by-step analysis of each of the preparer penalties under the Code,

Read More »