IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

IRS Issues Proposed Regulations under Section 6751(b)

Section 6751(b) Penalty Approval Circuit Split

How to Successfully Fight the Section 6721(e) Intentional Disregard Penalty

IRS Tax Penalties and the Tax Professional Reliance Defense

Ninth Circuit Opines on Section 6751(b) and its Application to Assessable Penalties

IRS Notice 2007-83 Declared Unlawful Under the Administrative Procedure Act

The IRS’s Voluntary Disclosure Practice (VDP): IRS Revises Form 14457

Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code Section 6751(b)(1)

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

Tax Court Grants Innocent Spouse Relief

Defenses to Section 6038 IRS Penalties

Accuracy-Related Penalties: The Burdens of Proof and Production

Section 6700 Penalties – False or Fraudulent Statements

Reasonable Cause: An Estate’s Defense Against IRS’s Late-Filing Penalties

Qualified Amended Returns: How to Avoid Tax Penalties

The Art of the Tax Disclosure: How to Avoid Tax Penalties By Disclosing a Return Position

Do FBAR Penalties Survive Death? A Texas Court Says “Yes”