The IRS has advised (CCA_2011051307555350) that generic legal advice (AM 2007-017), which concluded that there was no limitations period applicable to the assessment of a section 6695A penalty, was drafted before 2007 amendments to section 6696(d)(1) and, thus, is no longer correct advice.
"See, Advice on Assessment of Gross Valuation Misstatement Penalty is No Longer Valid, 2011 TNT 113-68"
Posted by Adam Fleischer, Associate Editor, Wealth Strategies Journal

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