Areas of Practice


PENALTY ABATEMENT

Tax penalties can be onerous. We assist clients with a variety of tax penalty issues, including:

  • Procedures for requesting abatement or non-assertion
  • Penalties arising during an audit
  • Penalties asserted by collections
  • Substantial authority standard
  • Claims for refund
  • Realistic possibility of success standard accomplishing full disclosure
  • Reasonable cause and ordinary business prudence
  • Hardship
  • Appealing penalty determinations

 
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