Caroline D. Ciraolo presented "Penalties Above 20%: What Are They, When Are They Applied, And How Do You Defend?" at the 65th Annual Taxation Conference

During this panel, attendees discussed the various penalties, when they may apply, and applicable defenses, when the IRS seeks to impose accuracy-related penalties in excess of 20%. 

Other topics included gross valuation misstatements, undisclosed non-economic substance transactions, undisclosed foreign financial asset understatements, and undisclosed listed and other avoidance transactions.