Dante’s Inferno for Taxpayers: A Journey to the Realm of Federal Tax Penalties

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Dante’s Inferno for Taxpayers: A Journey to the Realm of Federal Tax Penalties

Program Originally Presented Wednesday, December 8, 2021

This advanced CLE presentation is designed to provide an update on federal tax penalties under the Internal Revenue Code, including available defenses and related procedural issues. While our tax system is designed to involve voluntary compliance, penalties serve to provide incentives for taxpayers to comply with their obligations.

Panelists will address the following:

• Accuracy-related penalties under section 6662 of the Code, and the related defenses
• The civil fraud penalty under section 6663 of the Code and related matters, including the treatment of spouses filing a joint return
• Reportable transaction penalties including failure to furnish information, and failure to maintain lists of advisees, along with the impact of the full-payment rule on judicial review
• Affordable Care Act penalties, including penalties assessed in connection with Forms1094-C and 1095-C, Section 4980H penalties, and repayment of excess advance premium credit payments
• Foreign reporting tax penalties, including FBAR penalties and penalties for failure to report on foreign corporations and partnerships
• Employment tax penalties, including the trust fund recovery penalty, as well as related civil and criminal enforcement
• Enforcement priorities

Attend to hear valuable updates and guidance regarding federal tax penalties.

Panelists:
Professor Andrew Weiner
Director, Graduate Tax Program, Practice Professor of Law
Temple University Beasley School of Law

Beverly Winstead, Esq.
The Law Office of Beverly Winstead, LLC
Director, Low Income Tax Clinic
University of Maryland Law School, Baltimore

James R. Malone, Jr., Esq.
Principal, Post & Schell, P.C.
Philadelphia

0063ODV