2010/02/26

The realistic possibility standard – final regulations.: An article from: The Tax Adviser

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This digital document is an article from The Tax Adviser, published by American Institute of CPA’s on September 1, 1992. The length of the article is 940 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: The penalty and a standard for measuring the behavior of tax preparers who use methods of questionable merit when preparing returns is included in IRC 6694(a). The regulation pertains to tax treatments that result in tax underpayments. It establishes that the preparer must have an expectation that the treatment has a reasonable possibility, defined as a 33% chance, of surviving an IRS challenge. The penalty is $250 for understating the tax by an unrealistic method and $1000 for willful understatement, but can be mitigated by several safe harbor provisions in the regulation.

Citation Details
Title: The realistic possibility standard – final regulations.
Author: David R. Ward
Publication: The Tax Adviser (Magazine/Journal)
Date: September 1, 1992
Publisher: American Institute of CPA’s
Volume: 23 Issue: n9 Page: 593(2)

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