Notice 2009-05 provides guidance regarding implementation of the tax return preparer penalty under IRC Sec. 6694(a), as amended by the Tax Extenders and Alternative Minimum Tax Relief Act of 2008, Div. C. of Pub. L. No. 110-343, 122 Stat. 3765 (October 3, 2008) (the 2008 Act).
According to the Notice:
With this notice, the Treasury Department and the IRS are simultaneously issuing final regulations revising the regulatory scheme governing tax return preparer penalties in accordance with the amendments to IRC Sections 6694 and 6695 (and related provisions under sections 6060, 6107, 6109, 6696, and 7701(a)(36)) in both the 2008 Act and the Small Business and Work Opportunity Tax Act of 2007, Title VIII-B of Pub.L. No. 110-28 (121 Stat. 190) (May 25, 2007) (the 2007 Act). Section 1.6694-2 of the final regulations, however, does not provide substantive guidance reflecting certain amendments to section 6694(a) made by the 2008 Act. Rather, the Treasury Department and the IRS are reserving §1.6694-2(c) in those final regulations and are issuing this notice. This notice provides interim guidance on the 2008 Act's changes to section 6694(a) and solicits public comments on this guidance.
Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.
The New York Times has published an article on the conviction of a father and son for tax evasion. The article explains that the defendants used family members, offshore accounts, and forged documents to conceal the sale of a hotel...
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