TAX CONTROVERSY 360
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights

Taxpayers Should Prepare for the Next Penalty Battleground

By , and on May 31, 2019
Posted In IRS Audits, IRS Guidance, Tax Refunds, Uncategorized

The IRS is using a new tool from its arsenal to enforce compliance for tax refund and credit claims: the Internal Revenue Code Section 6676 penalty. Taxpayers and their advisers need to be aware of the mechanics of this penalty and how best to avoid it being sustained.

Andrew R. Roberson, Kevin Spencer and Evan Walters authored a comprehensive article on IRC Section 6676. They discuss:

  • The origins of IRC Section 6676
  • How to contest the penalty and privilege concerns
  • What taxpayers who are considering filing—or have already filed—refund claims should keep in mind now that the penalty is the IRS’s favorite new compliance tool

Read the article here.

Tags: Internal Revenue Code Section 6676, Internal Revenue Service, IRC, IRC Section 6662, IRC Section 6662 penalty, IRC Section 6676, IRC Section 6676 penalty, IRC Section 7701, IRS, JCT, Joint Committee on Taxation, Priority Guidance Plan, tax audit, Tax Cuts and Jobs Act, tax refund claims, TIGTA, Treasury Inspector General for Tax Administration, Treasury Regulation Section 1.6664-4, US Department of Treasury
Evan Walters
Evan Walters focuses his practice on US and international taxation. He has experience across a wide range of issues involving corporate and partnership taxation. Read Evan Walter's full bio. 

Kevin Spencer
Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of Tax degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court. Read Kevin Spencer's full bio.

McDermott Will & Emery
McDermott Will & Emery partners with leaders around the world to fuel missions, knock down barriers and shape markets. Our team works seamlessly across practices, industries and more than 20 locations to deliver highly effective—and often unexpected—solutions that propel success. More than 1,200 lawyers strong, we bring our personal passion and legal prowess to bear in every matter for our clients and the people they serve.

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