Review of the Civil Penalty Provisions Contained in the Internal Revenue Code: Hearings Before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, One Hundredth Congress, Second Session, March 31; and July 28, 1988, 4. sējumsU.S. Government Printing Office, 1989 - 631 lappuses |
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abated additional administration alternative minimum tax American Bar Association amount apply appropriate asserted audit Bad check believe Chairman PICKLE civil tax penalties Commissioner Committee complex comply conduct Congress correct Court deductions delinquency effect employees enacted Enrolled Agents errors estimated tax example excise tax failure to file failure to pay Form fraud penalty imposed income tax increased individual information reporting information return interest Internal Revenue Code Internal Revenue Service IRS penalty issue J. J. Pickle legislation negligence penalty noncompliance notice payment payor penalized penalty assessments penalty for failure penalty structure penalty system percent preparer penalties problem procedures question reasonable cause recommendations regulations rules sanctions SCHULZE small business specific standard statement statute substantial authority substantial understatement penalty Task Force tax deficiency Tax Executives Institute tax laws tax liability tax shelter tax system taxpayer TOBIAS Treasury underpayment voluntary compliance withholding
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398. lappuse - Congress or by these rules, a presumption imposes on the party against whom it is directed the burden of going forward with evidence to rebut or meet the presumption, but does not shift to such party the burden of proof in the sense of the risk of nonpersuasion, which remains throughout the trial upon the party on whom it was originally cast.
469. lappuse - Thank you again for the opportunity to appear before you today. And I will be happy to answer any questions that you may have at the appropriate time.
388. lappuse - They are provided primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense of investigation and the loss resulting from the taxpayer's fraud.
435. lappuse - ... with an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate.
20. lappuse - However, the negligence penalty extends by reason of such negligence to only that portion of the understatement attributable to the misreported item. The civil fraud penalty generally is imposed only when the taxpayer's behavior extends substantially beyond a failure to take reasonable care in the preparation of the required return and involves an intentional or reckless underpayment of taxes owed. This penalty is currently equal to 75 percent of the portion of the underpayment attributable to fraud,...
421. lappuse - Willfully aids or assists in, or procures, counsels, or advises the preparation or presentation under, or in connection with any matter arising under, the internal revenue laws, of a return, affidavit, claim, or other document, which is fraudulent or is false as to any material matter, whether or not such falsity or fraud is with the knowledge or consent of the person authorized or required to present such return, affidavit, claim, or document; . . . shall be guilty of a felony...
397. lappuse - The fraud meant is actual, intentional wrongdoing, and the intent required is the specific purpose to evade a tax believed to be owing.
426. lappuse - The purpose is not alone to get tax information in some form but also to get it with such uniformity, completeness, and arrangement that the physical task of handling and verifying returns may be readily accomplished.
18. lappuse - ASSISTANT SECRETARY (TAX POLICY) DEPARTMENT OF THE TREASURY BEFORE THE SUBCOMMITTEE ON SELECT REVENUE MEASURES COMMITTEE ON WAYS AND MEANS US HOUSE OF REPRESENTATIVES Mr.