Recalculating Penalties and
Interest
Welcome to TaxMama’s Place
Home of the
08/15/11
© www.taxdebtanonymous.com 2011 Penalties
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Table of Contents
Meet Your Instructors
Introduction to penalties and their purpose
Dealing with Proposed Penalties
Dealing with Assessed Penalties
Penalties in detail
Preparer Penalties
Recomputing and Reducing penalties
Career Reducing penalties
Resources
Evaluations and Thanks!
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Who is Eva Rosenberg MBA, EA
Eva Rosenberg, EA, Your TaxMama® has been
teaching Enrolled Agents Exam review courses off and
on since developing the program for UCLA Extension
over 15 years ago. These days, she’s teaching her own
course online at www.irsexams.com
Eva has a BA in Accounting and an MBA in
International business. Your TaxMama® is a TaxWatch
columnist for Dow Jones' www.MartketWatch.com and
author of the ever-popular book, Small Business Taxes
Made Easy, published by McGraw-Hill – new edition –
just released!
As a speaker, TaxMama® is popular with both tax
professionals and taxpayers.
You can find her at www.TaxMama.com and subscribe
to her free daily podcast at www.TaxQuips.com
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Who is Tom Buck, CPA
Tom Buck, CPA is a published author, tax coach, teacher
And mentor. He has been a licensed CPA since 1971 and
has been in private practice since 1982.
Tom was chairman of the Nevada Society of CPAs Taxation Committee.
Tom has been representing taxpayers and solving IRS problems ever
since the landmark Casino employee cases in 1982.
The approach Tom takes and that he would like to pass on to you is this:
the “science” of the work is the law and how it should be applied. The
“art” is being able to counter any and all IRS measures which are not
supported by law. Does the IRS always follow the rules? Of course not,
so part of the “art” is really in forcing the IRS to obey the law. Of course,
having the tenacity of a bulldog is often the critical ingredient. In the final
analysis, once you determine what the outcome should be, then you
must be ready to take any detours necessary to get your client to the
finish line.
Tom is a willing and helpful teacher and looks forward to sharing his
hard-gained knowledge.
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Who is Sonya Wilt, EA
Sonya Wilt, BS in Management, EA and entrepreneur. A graduate of
Upper Iowa University, Fayette, and former student of Eva
Rosenberg’s Enrolled Agent Review Course, Sonya also has an
extensive background in management and accounting, small
business consulting, and employee training
Sonya’s desire to stay on top of the changes in tax law is two-fold:
1)
2)
To make sure her investments and entities are taking advantage of
every legal tax deduction available with adequate documentation,
and…
2) To provide our clients with accurate information so they may
make solid decisions in both resolving current tax issues and
legally protecting their future earnings.
Sonya and her partner, Tom Buck, CPA aggressively represent clients
before state and federal taxing authorities through audits, appeals
and collections.
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Introduction Purpose of Penalties –
Per IRS
1.
2.
3.
Penalties exist to encourage voluntary compliance by supporting the
standards of behavior required by the Internal Revenue Code.
For most taxpayers, voluntary compliance consists of preparing an
accurate return, filing it timely, and paying any tax due. Efforts made
to fulfill these obligations constitute compliant behavior. Most
penalties apply to behavior that fails to meet any or all of these
obligations.
The following factors support the public conviction that the tax system
is fair and the penalty is in proportion to the severity of the
noncompliance. Penalties encourage voluntary compliance by:
Defining standards of compliant behavior,
Defining consequences for noncompliance, and
Providing monetary sanctions against taxpayers who do not meet
the standard.
http://www.irs.gov/irm/part20/irm_20-001-001r.html#d0e406
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Penalties
Penalties –
Inevitable?
Or Abatable?
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Insignificant Penalties
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Your billable time - $100 - $500 per hour or so
Assessed negligence or preparer penalty of $250
IRC: 6694(a) Understatement of taxpayer's liability due to unrealistic position
What should you do?
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Some IRS Letters that include penalties
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
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Form 886-A, Explanation of Items;
Form 1273, Report of Estate Tax Examination Changes;
Form 2504, Agreement to Assessment and Collection of Additional Tax and Acceptance of
Overassessment. - NEVER SIGN THIS!
Form 4549, Income Tax Examination Changes—for agreed cases for individuals and
corporations;
Form 4549–A, Income Tax Examination Changes—for unagreed and accepted agreed cases
for individuals, corporations, taxable fiduciaries, and taxable small business corporations;
Form 4605, Examination Changes—Partnerships, Fiduciaries, Small Business Corporations,
and Domestic International Sales Corporations—used to report audit changes made to
partnership, fiduciary, and small business corporation returns;
Form 4605–A, Examination Changes—Partnerships, Fiduciaries, Small Business
Corporations, and Domestic International Sales Corporations—for unagreed and excepted
agreed cases for partnerships, fiduciaries, and small business corporations;
Form 4665, Report Transmittal—never send the taxpayer or power of attorney copies of Form
4665;
Form 4666, Summary of Employment Tax Examination.
Form 4667, Examination Changes—Federal Unemployment Tax
Form 4668, Employment Tax Examination changes Report and,
Form 5385, Excise Tax Examination Changes.
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When Penalty is Proposed
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Before the penalty is ever assessed, you have time to
make it go away. Use it!
Provide evidence to support reason for late filing
Provide evidence to support taxpayer’s illness or
incompetence causing delays
Provide evidence to support reasons for taking that
particular position
Provide evidence why the data was in error at the time the
return was prepared
Beg or Whine
….tears?
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When Penalty is Assessed –
to request abatement
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Once a penalty as been assessed –
Informal request
Form 843 Claim for Refund and Request for Abatement
Fast Track Mediation
IRS Appeals
Taxpayer Advocate Service
Tax Court Petition
Court of Claims or U.S. District Court (must pay taxes,
penalties and interest, first)
U.S. Court of Appeals
U.S. Supreme Court
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Informal Request
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Informal Claims for Refund Abatement may be submitted by
taxpayers.
Taxpayers who are not asking for a refund do not need to use Form 843,
Claim for Refund and Request for Abatement, to receive
consideration of the claim.
Collection may process the informal claims that are submitted; however,
if the taxpayer intends to file suit, the claim must be submitted on
Form 843, Claim for Refund and Request for Abatement, along with
the required payment. Collection is responsible for informing the
taxpayer of this process.
TaxMama Note: Without the rejection of the Form 843 claim, taxpayer
cannot file for a refund in court.
Appeals may receive Informal Claims for Refund Abatement from
Collection.
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Penalty Relief Criteria
Generally, relief from penalties falls into four
separate categories:
Reasonable Cause
Statutory Exceptions
Administrative Waivers
Correction of Service Error
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Penalty Relief – IRS Considerations
• Reasonable Cause
• Taxpayer’s Effort to Report the Proper Tax
Liability (Good Faith)
• Experience, Knowledge, Sophistication and
Education of Taxpayer
• Disasters – personal or public
• Reliance on Advice
• Reportable Transactions
• Non-tax Matters
• Advisor Independence
• Adequate Disclosure
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Reasonable Cause
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Reasonable cause is based on all the facts and circumstances in each
situation - taxpayer exercises ordinary business care and prudence in
determining their tax obligations but nevertheless failed to comply with
those obligations.
What happened and when did it happen?
During the period of time the taxpayer was non-compliant, what facts
and circumstances prevented the taxpayer from filing a return, paying
a tax, and/or otherwise complying with the law?
How did the facts and circumstances result in the taxpayer not
complying?
How did the taxpayer handle the remainder of their affairs during this
time?
Once the facts and circumstances changed, what attempt did the
taxpayer make to comply?
Reasonable cause does not exist if, after the facts and circumstances that
explain the taxpayer’s noncompliant behavior cease to exist, the taxpayer
fails to comply with the tax obligation within a reasonable period of time.
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Special Circumstances, Disasters –
Personal or Public
• Death, illness, Disability – provide dates and
circumstances
Alcoholism and substance abuse
Mental illness or dementia
Physical abuse or intimidation
•
•
•
•
Personal fires, floods, destruction of records
Presidentially declared disaster areas
Military service
Incarceration
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Other Explanations
Unable to Obtain records
Held by ex-spouse or partner
Employer filed BK
• Mistake – a pure and simple, honest-togoodness error
Error by taxpayer
Error by preparer
Error by Computer
Error by third party
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Statutory Exceptions –
Statute of Limitations
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Statute of Limitations on Assessments
• 3 years after the tax return is filed
• 6 years after filing, for substantial understatement 25%
of
gross income
Gross estate or gross gifts
Excise tax
• Indefinitely for false or fraudulent returns -IRC section
6501(c)(1)
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Statutory Exceptions –
Exceptions in the Code
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Statutory Interest Abatement
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IRC section 6205 provides for an interest-free adjustment when an employer
underreported and underpaid certain employment taxes if specific conditions are
met by the employer to report the error and pay the tax due. However, IRC section
6205 and related Treasury Regulations are silent in regard to penalties.
Consequently, IRS extended an Administrative Waiver to certain penalties. See
IRM 20.1.1.3.3.2, Administrative Waivers.
Effective Jan. 1, 2009, Treas. Reg. 31.6205–1 and Treas. Reg. 31.6302–1 have been
amended for qualified interest-free adjustments. When all conditions have been
met for an employer to qualify for an interest-free adjustment, "the amount timely
paid will be deemed to have been timely deposited by the employer. " In other
words, "tax deemed to have been timely deposited " is not subject to the Failure to
Deposit (FTD), Failure to Pay (FTP), and Failure to File (FTF) penalties. See IRM
21.7.2.5, Adjusted Employer's Federal Tax Return or Claim for Refund, IRM
20.1.2, Failure to File/Failure to Pay Penalties, and IRM 20.1.4, Failure to Deposit
Penalty, for required procedures and additional information.
We’re going to talk more about this a little later today
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Administrative Waivers
1.
2.
3.
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The IRS may formally interpret or clarify a provision to provide administrative relief
from a penalty that would otherwise be assessed. An administrative waiver may be
addressed in either a Policy Statement, News Release, or other formal
communication stating that the policy of the IRS is to provide relief from a penalty
under specific conditions.
An administrative waiver may be necessary when there is a delay by the IRS in:
Printing or mailing of forms,
Publishing guidance (e.g. writing of Regulations), or
Other conditions.
An example of an administrative waiver is Notice 93–22, 1993-1 C.B. 305. This
allowed individuals who requested an automatic four-month extension of time to
file an income tax return, an extension of time without remitting the unpaid amount
of any tax properly estimated to be due. See Treas. Reg. 1.6081–4.
Real-life example – when partnership extensions were changed from 4 months to 3months. IRS didn’t highlight the change in What’s New or make any special
announcements.
I didn’t notice it and filed about 20 partnerships (each with 10-40 partners) late. Penatlies
would have run into 10s of thousands of dollars! I would have had to pay them!!!
© www.taxdebtanonymous.com 2011 Penalties
IRS Penalties in Detail
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IRS penalties, as set out in the Internal Revenue Code, are imposed to
"enhance voluntary compliance." There are over one hundred-forty
separate IRS penalty provisions.
Common IRS civil law penalties include the penalty for filing a fraudulent
return, the accuracy related penalties, the penalty for failure to timely
file a return, the penalty for failure to timely pay a tax, and the frivolous
return penalties.
In addition, there are a variety of preparer penalties. We’ll go into them in
more depth in a minute.
Let’s start with at taxpayer penalties – and how to abate them.
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File and Pay
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§Sec. 6651(a)(1) Failure to file a return - 5% of the unpaid balance for each month or part of a
month the return is late, maximum 25%. More than 60 days late – The
minimum is the lesser of $100 or the tax due
§Sec. 6651(a)(2) - Failure to pay tax -
The penalty for failure to timely pay a tax is set out in IRC Section 6651(a)(2) &
(3). This penalty is equal to 0.5% per month, up to 25% of the amount shown
as due on a return.
§Sec. 6651(f) - Fraudulent failure to file a tax return -
15% of tax balance per month, maximum 75%
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Certain Information Returns
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§ 6652 – a) Failure to file 1099-Int or 1099-PATR for amounts under $10
penalty is $1 per report, up to $1,000 - (1) section 6042 (a)(2) (relating to payments
of dividends aggregating less than $10), or (2) section 6044 (a)(2) (relating to
payments of patronage dividends aggregating less than $10).
b) Failure to report tips - In the case of failure by an employee to report to his
employer on the date and in the manner prescribed therefore any amount of tips
required to be so reported by section 6053 (a) which are wages (as defined in
section 3121 (a)) or which are compensation (as defined in section 3231 (e)), unless
it is shown that such failure is due to reasonable cause and not due to willful neglect,
there shall be paid by the employee, in addition to the tax imposed by section 3101
or section 3201 (as the case may be) with respect to the amount of tips which he so
failed to report, an amount equal to 50 percent of such tax.
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Exempt Orgs
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§ 6652 (c) - Returns by exempt organizations and by certain trusts
(1) Annual returns under section 6033(a)(1) or 6012(a)(6) (A) Penalty on organization In the
case of - (i) a failure to file a return required under section 6033(a)(1) (relating to returns
by exempt organizations) or section 6012(a)(6) (relating to returns by political
organizations) on the date and in the manner prescribed therefore (determined with
regard to any extension of time for filing), or (ii) a failure to include any of the information
required to be shown on a return filed under section 6033(a)(1) or section 6012(a)(6) or
to show the correct information, there shall be paid by the exempt organization $20 for
each day during which such failure continues. The maximum penalty under this
subparagraph on failures with respect to any 1 return shall not exceed the lesser of
$10,000 or 5 percent of the gross receipts of the organization for the year. In the case
of an organization having gross receipts exceeding $1,000,000 for any year, with
respect to the return required under section 6033(a)(1) or section 6012(a)(6) for such
year, the first sentence of this subparagraph shall be applied by substituting ''$100'' for
''$20'' and, in lieu of applying the second sentence of this subparagraph, the maximum
penalty under this subparagraph shall not exceed $50,000.
Managers penalties? - http://www.taxalmanac.org/index.php
/Internal_Revenue_Code:Sec._6652._Failure_to_file_certain_information_returns,_registratio
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Accuracy
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§ 6662 - Accuracy related penalty
The accuracy-related penalty is set out in IRC Section 6662. This penalty is 20% of the
amount of the portion of the understatement of tax attributable to the conduct being
penalized.
Accuracy penalties include the "negligence or disregard of rules or regulations" penalty,
the "substantial understatement of income tax" penalty, the penalty for "substantial
valuation misstatement," the penalty for "substantial overstatement of pension
liabilities," and the penalty for substantial valuation misstatement in connection with
gift tax or estate tax.
They Can be assessed due to:
(1) Negligence or disregard of rules or regulations.
(2) Any substantial valuation misstatement
(3) Substantial understatement of tax -- More than the greater of 10% of actual amount
due or $5000
Certain substantial valuation misstatements may cause a doubling of the penalty rate to
40%.
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Fraud and Frivolity
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§ 6651 (f) - The Fraudulent Failure to File Penalty includes penalties of 15% per month
up to 75%.
§ 6663 - The Fraudulent Return Penalty is set out in IRC Section 6663. This penalty is
"75% of the portion of the underpayment [of tax] which is attributable to fraud." The
fraudulent failure to file return penalty is set out in IRC Section 6651(f). This penalty
also has a maximum 75% rate.
§ 6673 – Frivolous Tax Court action - Maximum $25,000 if position is groundless,
intentional delay, frivolous or failed to follow administrative remedies
§ 6702 The frivolous return penalty is set out in IRC Section 6702. This penalty imposes
a $5,000 fine for filing a frivolous income tax return. The penalty applies to an
individual who files a return of tax on behalf of a tax shelter.
http://www.taxalmanac.org/index.php/Internal_Revenue_Code:Sec._6702._Frivolous_tax_submissions
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Trust fund penalty
§ 6662 – Trust Fund Penalty (also known as the 100% Penalty)
This penalty may be assessed against any and all “responsible” parties.
IRS procedure for Trust Fund Penalty Cases
http://www.irs.gov/irm/part8/irm_08-025-002.html
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Willfulness
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These are recent penalties. IRS finally got the authority to do something
about those people who’ve been thumbing their noses against IRS.
What does ‘willful’ mean?
§ 7201 – Willful attempt to evade or defeat any tax –
Felony - up to $100,000 fine or 5 years in prison or both. $500,000 for corp.
§ 7202 – Willful failure to collect or pay over tax Felony - up to $250,000 and/or 5 years in prison ($500,000 for corporations)
§ 7203 – Willful failure to pay tax or file a tax return or supply information Misdemeanor - up to $100,000 fine or one year in prison or both. ($200,000 for corp.)
§ 7206(1) - Perjury and fraud -- knowingly filing or helping in filing false return Felony - up to $250,000 fine or 3 years in prison or both. ($500,000 for corp.)
Note: this penalty also applies to any person who aids or abets.
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Willfulness, continued
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§ 6662 – Attempts to Interfere with administration of IRS laws - This law has to do
with attempts to intimidate or impede any agents acting in an official capacity.
Felony – up to 3 years in prison or fine up to $250,000 or both ($500,000 for corps)
Title 18 USC § 371 – Conspiracy to commit offense to or defraud the United States
This law refers specifically to a conspiracy between two or more people. If there is
such a conspiracy then if one or more of the conspirators commits such an act, they
can all be held guilty.
Felony – each conspirator – up to 5 years in prison or a fine up to $250,000, or both
($500,000 for corps)
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Summary of Preparer Penalties
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Summary of Preparer Penalties
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Assessed Penalties and Interest
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Once IRS assesses penalties, some penalties are
computed based on a number of months of noncompliance, or tardiness.
Then, the interest is computed on the taxes and
penalty balances each month.
IRS doesn’t always get their computations right.
How can you check IRS’s computations?
Is it worthwhile to check IRS’s computations?
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Worthwhile checking?
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ABSOLUTELY!
Getting the right penalty balance, in the right month, will
reduce all the related interest.
Correcting penalty assessments for high-volume business
clients, or clients with high taxes and penalties – can
result in a saving of thousands of dollars.
Some penalties have statutory reductions, where the right
timing can save hundreds of thousands of dollars.
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How Can you Check IRS’s Calculations?
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You can set up a spreadsheet with the interest rates for each
period built in and build the computation yourself.
Manually enter each penalty, on each date
Interest rates change each quarter
How many hours will that take?
Or you can use well-tested tools to do all that for you? And still
charge your clients for your expertise, not the time.
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TimeValue Software
TimeValue Software - www.TimeValue.com
One of the oldest (perhaps the original) tools.
IRS uses their tools extensively
Includes corporation and (most) state computations
Just plug in your client’s numbers – and let the software do all the
computations.
Get 20% discount on TaxInterest Software
Get over 50% on Payroll Bundle – PayrollPenalty and Tax941
Tell them TaxMama sent you – or use the flyers in your Resources
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TimeValue TaxInterest
Includes quarterly updates – be sure to install
before any new computations.
• Enter dates – current, due date, date filed
• Select penalties that were assessed (check
boxes)
• Enter changes and dates – like amendments,
and suspensions of time
• Compute
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Suspend Interest in TimeValue
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Suspend Interest
The Suspend interest event stops the running of interest until you enter a
Resume interest event. The suspension applies to all interest
computations. Interest can be suspended for a number of reasons.
For example, if a waiver of restrictions on the assessment of a deficiency
has been filed and if notice and demand by the IRS is not made within
30 days, interest is suspended from that point until notice and demand
is made. §6601(c).
http://www.irs.gov/irb/2005-28_IRB/ar15.html
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Suspend or Abate Interest Rules
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IRM 20.2.7 explains the application of interest rules on accounts where interest
was:
Excessive, barred by statute, erroneously or illegally assessed [ IRC
6404(a)];
Attributed to certain unreasonable errors or unreasonable delays by
the IRS [ IRC 6404(e)(1)];
Assessed on an erroneous refund [ IRC 6404(e)(2) ];
Due on an additional liability that was not identified by the IRS in a
timely manner [ IRC 6404(g)];
Disregarded for a period of time due to a taxpayer's participation in a
combat zone [ IRC 7508];
Disregarded for a taxpayer qualifying for Military Deferment [Title 50
Appendix section 570 USC]; and
Due on an account for a taxpayer located in a declared disaster area
[ IRC 7508A].
http://www.irs.gov/irm/part20/irm_20-002-007r.html
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Evaluate the Effect of Exam Concessions –
Before you agree
Page 40
Facts Roger Santiago and the IRS agreed that a $1,000 credit taken in
2006 should have been taken in 2007. Santiago wants to know the
amount due as of July 1, 2008. In addition, he wants his Interest and
Penalty Detail Report to read “06 Exam Adjustment” instead of “Tax”
and “06 Credit Allowed” instead of “Payment.”
Solution The interest due as of July 1, 2008, is $80.88.
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Payment Allocation and Correction
Page 41
For a variety of reasons, taxpayers may wish to specifically designate the application
of payments. For example, the interest amount may be deductible or the payment
might be used to satisfy a liability that is running interest at a higher rate than another
item.
The IRS spells out its position with respect to allocation of payments in Rev. Proc. 8458, and Treas. Reg. §301-6621-2T. If the taxpayer makes no designation, the payment
is applied first to tax, then motivated tax, then penalties, and finally to interest.
The IRS default payment allocation rules may not be binding on the taxpayer who
makes timely designation as to how payments should be applied. See, for example,
Perkins v. Commissioner, 92 T.C. 749 (1989), in which the court overruled Rev. Proc.
84-58 and allowed the taxpayer to allocate an entire payment to interest.
You may want to correct the application of payments – or locate payments
made by your client that were not applied to the correct year – especially
including
Garnishments and levies
ES payments that did not specify a year.
Amended returns with additional refunds
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Payroll Tax Penalties
When it comes to payroll, you can barely turn around without
being hit with a penalty.
Late payment penalties are harsh – and so is the penalty for
paying with the 940 or 941, instead of EFTPS.
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TimeValue PayrollPenalty
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T h e IR S u s e s o n ly o n e m e th o d t o c a lc u la te t h e p e n a lt ie s fo r fa ilu r e -to -d e p o s it.
H o w e v e r , R e v e n u e P r o c e d u r e s 9 9 -1 0 a n d 2 0 0 1 -5 8 a llo w u s e o f o th e r
c a lc u la tio n m e th o d s th a t a r e fa r m o r e b e n e fic ia l to th e ta x p a y e r .
P a y r o llP e n a lt y fa ilu r e -to -d e p o s it p e n a lty -a b a te m e n t s o f tw a r e u s e s u p to 2 5 0
a lte r n a tiv e m e th o d s o f a llo c a tin g th e d e p o s its to g iv e y o u th e lo w e s t
p o s s ib le p e n a lty f o r 9 4 0 , 9 4 1 , 9 4 3 , a n d 9 4 5 fa ilu r e -to -d e p o s it p e n a ltie s .
These Rev Procs allow you to re-allocate payments to avoid or reduce the
immediate late payment penalties (1-16 days), and leave those older
penalties intact where it’s too late to apply payments.
By re-allocating payments, you not only reduce the 10% - 15% penalties, you
also reduce the related interest.
Companies with large payrolls are very susceptible to such penalties.
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Career Reducing Payroll Penalties
Page 44
You can make an entire career out of getting these
penalties reduced.
How?
IRS allows tax practitioners to collect a contingency fee for representation.
Imagine walking into a multi-million dollar corporation and making them this offer:
If I can reduce your payroll tax penalties and interest, will you pay me 20%
(or more) of any savings I bring you? Pay me nothing if I don’t succeed.
(Don’t tell them HOW you did it – just do the work on your laptop in a conference room or
empty office. Simply log into https://www.payrollpenalty.com )
Not only will you get the fee – you will get an ongoing
client, too!
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Career Reducing Penalties
Page 45
Think about yourself – and why you’re here.
You’ve lacked confidence about getting penalties and
interest reduced.
You didn’t know how to research getting penalties and
interest reduced.
You didn’t know who to ask when it comes to getting
penalties and interest reduced.
And you didn’t want to look ignorant.
Wouldn’t you have given anything to have someone do it
for you?
Don’t you think other tax pros would jump at the chance to
turn over those problems to you?
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Summary
Page 46
Remember, “Penalties exist to encourage voluntary compliance by
supporting the standards of behavior required by the Internal
Revenue Code.”
If you can convince IRS that your client has erred, but once, and has
learned from his/her error – you may be able to abate all
penalties.
If not, either fight them or reduce the impact by checking IRS’
calculations.
In fact, you can build an entire career around abating penalties.
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© www.taxdebtanonymous.com 2011 Penalties
Resources
Page 47
2011 IRS Processing Codes and Information http://www.irs.gov/pub/irs-utl
/document6209_redacted.pdf
IRS procedure for Trust Fund Penalty Cases http://www.irs.gov/irm/part8/irm
_08-025-002.html
IRS Penalty Handbook - http://www.irs.gov/irm/part20/irm_20-001-001r.html
IRS Penalty Relief http://www.irs.gov/irm/part20/irm_20-001-005.html#d0e969
Form 843 Claim for Refund and Request for Abatement http://www.irs .g ov/pub/irs
-pdf/f843.pdf
Fast-Track Mediation http://www.irs.gov/individuals/article/0,,id=96779,00.html
IRS Publication 3605 – Fast Track Mediation (FTM) http://www.irs.gov/pub/irs-pdf
/p3605.pdf
IRS Form 14017 – Request for FTM http://www.irs.gov/pub/irs-pdf/f14017.pdf
IRS Appeals - http://www.irs.gov/individuals/article/0,,id=98180,00.html
Taxpayer Advocate Service http://www.irs.gov/advocate/
08/15/11
© www.taxdebtanonymous.com 2011 Penalties
CPE Link
Page 48
Thanks for coming.
Remember to give CPE Link your evaluations.
Drop by to sign up for other TaxMama classes –
http://www.cpelink.com/teamtaxmama
The next class in the series is – Representing Your Client at a
1040 Audit – Office or Field
Series are available as Self-Study or Resources:
• The Tax Practice Series - Taxpayer representation – Collections,
Offers In Compromise, other payment alternatives
• TaxMama’s Courses
08/15/11
© www.taxdebtanonymous.com 2011 Penalties