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.
On Friday, May 12, Arnstein & Lehr LLP partner Robert E. McKenzie was awarded the Jules Ritholz Award by the American Bar Association Civil and Criminal Tax Penalties Committee. The award recognizes Mr. McKenzie’s outstanding integrity, dedication and achievement in the field of tax controversy.