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Tax PenaltiesAnyone who has ever faced a tax problem with the IRS or a state-taxing agency knows the magnitude of the penalties levied by the government for non-execution. Because of the rapid increase of high tax penalties and interest, a manageable tax problem often quickly transforms into unmanageable disaster. San Francisco Tax Attorneys are often asked to help clients deal with tax penalty issues. The Internal Revenue allows taxpayers to avoid tax penalties provided there is a good excuse, known as reasonable cause. Reasonable cause is based on all the facts and circumstances in each situation and allows the Internal Revenue Service to provide relief from a penalty that would otherwise be assessed. Reasonable cause relief is generally granted when the taxpayer exercises ordinary business care and prudence in determining their tax obligations but is unable to comply with those obligations. In the interest of equitable treatment of the taxpayer and effective tax administration, the non-assertion or abatement of civil penalties based on reasonable cause or other relief provisions must be made in a consistent manner and should conform with the considerations specified in the Internal Revenue Code. Reasonable cause relief is not available for all penalties; however, other exceptions may apply. For those penalties where reasonable cause can be considered, any reason, which establishes that the taxpayer exercised ordinary business care and prudence, but was unable to comply with a prescribed duty within the prescribed time, will be considered. The wording used to describe reasonable cause provisions varies. Some IRC penalty sections also require evidence that the taxpayer acted in good faith or that the taxpayer's failure to comply with the law was not due to willful neglect. Taxpayers have reasonable cause when their conduct justifies the nonassertion or abatement of a penalty. Each case must be judged individually based on the facts and circumstances at. Experienced San Francisco Tax Attorneys review each client's special situation to determine if any penalties might be waived. If our tax attorneys determine that a reasonable cause might exist, we aggressively pursue the abatement of the penalty.
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