More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more