When the IRS audits a taxpayer and determines that additional tax is due, the taxpayer may be subject to penalties in addition to the tax due. Further, the tax practitioner involved in preparing that tax return may also be subject to penalties. This course will cover the standards applicable to both the taxpayer and tax practitioner when the IRS determines whether to impose penalties.
The course will review the relevant standards, including reasonable basis, substantial authority, and how to make adequate disclosure. Knowing and applying these standards will help the practitioner and taxpayer avoid IRS penalties.
Learning Objectives:
Kostelanetz LLP
Partner
[email protected]
(212) 808-8100
Michael Sardar has extensive experience in a wide range of tax controversy and white-collar criminal defense matters. Mr. Sardar represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.