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.
1. A CHANGING IRS
1.10 Because of Congressional cuts in IRS budgets its workforce continued to shrink until 2008. In 2009 and 2010 the IRS had its budgets grow and its workforce grew. In 2011 the IRS budget was frozen and its workforce shrank. In 2012, 2013, 2014 2015 and 2016 Congress stupidly cut the IRS budget and its workforce has shrunk dramatically.
To read the ‘2016 IRS Representation Update,’ in full, click here.