Procedural Requirements for Imposition of Penalties and Additions to Tax
The Internal Revenue Service Restructuring Act required that each notice imposing a penalty include the name of the penalty, the Code section imposing the penalty, and a computation of the penalty. The Act also requires the specific approval of IRS management to assess all non computer generated penalties unless excepted. This provision does not apply to failure to file penalties, failure to pay penalties, or to penalties for failure to pay estimated tax.
Robert McKenzie was recognized in an article in the April/May 2009 edition of CPA Magazine entitled the “Top 40 Tax Advisors to Know During a Recession.” State society and national association of CPAs and accountants nominated the candidates. Each candidate was then asked to submit words of advice about tax planning during a recession.
106 Swiss banks have signed agreements to provide information about U.S. account holders. "The current…