This is the property of the Daily Journal Corporation and fully protected by copyright. It is made available only to Daily Journal subscribers for personal or collaborative purposes and may not be distributed, reproduced, modified, stored or transferred without written permission. Please click "Reprint" to order presentation-ready copies to distribute to clients or use in commercial marketing materials or for permission to post on a website. and copyright (showing year of publication) at the bottom.
Subscribe to the Daily Journal for access to Daily Appellate Reports, Verdicts, Judicial Profiles and more...

Tax

Sep. 2, 2020

IRS waives penalties for reasonable cause, but what’s that?

The tax code is chock full of penalties, so you always want to behave reasonably and in good faith. One of the biggest and most misunderstood grounds of relief from penalties is “reasonable cause.” Some penalty defenses involve an absence of willful neglect, too. Isn’t that proving a negative? Yes, and guess who wins in a tax penalty stalemate? The IRS, of course.

Robert W. Wood

Managing Partner
Wood LLP

333 Sacramento St
San Francisco , California 94111-3601

Phone: (415) 834-0113

Fax: (415) 789-4540

Email: wood@WoodLLP.com

Univ of Chicago Law School

Wood is a tax lawyer at Wood LLP, and often advises lawyers and litigants about tax issues.

The tax code is chock full of penalties, so you always want to behave reasonably and in good faith. One of the biggest and most misunderstood grounds of relief from penalties is "reasonable cause." Some penalty defenses involve an absence of willful neglect, too.

Isn't that proving a negative? Yes, and guess who wins in a tax penalty stalemate? The IRS, of course.

You bear the burden of substantia...

To continue reading, please subscribe.
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!

Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)

Already a subscriber?

Enewsletter Sign-up