In a recent Tax Notes article by Kristen A. Parillo entitled “New IRS Practice Unit Explains Penalty Relief,” Yoram Keinan discusses the merits of the IRS's latest guidance that overviews the reasonable cause exception for penalties.
Excerpts from the article are below:
“There is no big news here, but I think the practice unit is well organized and provides great guidance,” said Yoram Keinan of Kostelanetz & Fink LLP. “It provides a great start for practitioners.”
Keinan noted that Treasury and the IRS have in the past provided a handful of highly limited examples regarding reasonable cause in regulations. However, because the universe of what could constitute reasonable cause is so broad, he said he wouldn’t expect the IRS to give detailed examples in a practice unit.
“To provide helpful examples, the IRS — with Treasury — must put together lengthy regulations,” Keinan said. It wouldn’t be in the IRS’s best interest to provide detailed examples in a practice unit of what it considers reasonable cause and what it doesn’t, he added.
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