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Tax Notes Quotes Zhanna Ziering on IRS's Automatic Assessments of International Information Return Penalties

December 16, 2019, Tax Notes

The IRS is investigating complaints that penalties are being automatically assessed against some taxpayers using the delinquent international information return submission procedures.

Those taxpayers are wondering whether the IRS ever considered the reasonable cause statement they were required to attach to their delinquent filings, said Carolyn Schenck, assistant division counsel (International) in the IRS Office of Chief Counsel.

. . .

Schenck said the IRS will work as quickly as it can to determine why penalties are being automatically assessed against some taxpayers. In the meantime, taxpayers and their advisers should continue to file reasonable cause statements and make use of every available IRS resource, including going to Appeals, to ensure the agency is hearing why the taxpayer isn’t subject to penalties, she added.

Zhanna Ziering of Caplin & Drysdale said she appreciated hearing that the IRS is looking into the matter, but she stressed that the agency should also consider the costs to taxpayers who must pay an attorney to help them prepare another reasonable cause statement and fight the penalty assertions.

Schenck said she understands the frustrations of taxpayers trying to undo an automatic assertion of penalties. “We know we’re dealing with real people with real penalties and real issues here, and we want to make sure these things are resolved with as little angst as possible,” she said.

For the full article, please visit Tax Notes’ website (subscription required).


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