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IRS Penalty Protection
Contains material from Jan 2021
IRS Penalty Protection
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The IRS has long taken the position that taxpayers rely on IRS publications and instructions to forms at their peril, and courts have agreed. That position also applies to most FAQs, some of which even include disclaimers to that effect. Explore the current state of the law on the extent to which IRS written statements describing or interpreting the law can be used to defeat the assertion of penalties.
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Penalty Protection (Jan 2021)
Professor Alice G. Abreu
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Session 1
—60 mins
Penalty Protection (Jan 2021)
The IRS has long taken the position that taxpayers rely on IRS publications and instructions to forms at their peril, and courts have agreed. That position also applies to most FAQs, some of which even include disclaimers to that effect. Explore the current state of the law on the extent to which IRS written statements describing or interpreting the law can be used to defeat the assertion of penalties.
Originally presented: Dec 2020 Taxation Conference
Professor Alice G. Abreu,
Temple University Beasley School of Law - Philadelphia, PA