New Guidance Provides Limited Relief from Penalties for Failure to Comply with List Maintenance Requests

By Bryan C. Skarlatos and Megan L. Brackney
ournal of Tax Practice & Procedure
April - May 2013 Edition

Imagine you are a partner at an accounting fi rm and you discover that, several years ago, one of your partners provided advice to a few clients regarding a type of retirement plan that was a reportable transaction. After auditing the taxpayers, the IRS is now focusing on your fi rm as a possible material advisor and has requested the fi rm to provide a list with respect to all reportable transactions for which it was a material advisor. Failure to provide the requested information within 20 days of the request can result in crushing penalties of as much as $10,000 per day!

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