History of noncompliance - As part of the Required Filing Checks, examiners determine whether the return was timely filed. Some audit indicators for the negligence component of the accuracy-related penalty are listed below. SBSE Compliance Examination Field Operations Employees.Ī component of the accuracy-related penalty involves taxpayer’s negligence or disregard of rules or regulations - Per IRC section 6662 (c), "negligence" is defined as any failure to make a reasonable attempt to comply with the provisions of this title, and the term "disregard" includes any careless, reckless or intentional disregard. The text has been renumbered and updated as necessary to reflect changes pursuant to the IRS reorganization such as the new organizational names and titles. (1) This transmittal reissues existing procedures. This section also provides techniques for recognizing, developing and finalizing penalty determinations discusses common taxpayer defenses, and furnishes guidelines for documenting the workpapers. Although each penalty has its own legal basis and standards (see Penalty Manual), there are commonalities for determining the applicability of penalties at the examiner’s level. This text complements the legal analysis of penalties provided in IRM 20.1, Penalty Manual, by providing guidelines and examination techniques to be considered and, when warranted, used to develop penalty issues. (1) This transmits a complete revision of Section 6, Penalty Considerations, of IRM 4.10, Examination of Returns, with changes.
FAILURE TO INFORM DEFINITION MANUAL
Penalty ConsiderationsĤ.10.6 Penalty Considerations Manual Transmittal
4.10.6.3.5.3 Reliance On Representative and/or Return Preparer.4.10.6.3.5 Soliciting the Taxpayer’s Explanations.
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