Penalties for Aiding and Abetting Understatement of Tax Liability

ID:
UILC:
CCA_2015041016033046
6701.00-00, 6694.00-00
Third Party Communication: None
Date of Communication: Not Applicable
Number: 201518017
Release Date: 5/1/2015
From:
Sent: Friday, April 10, 2015 4:03:30 PM
To:
Cc:
Bcc:
Subject: RE: 6694(b) vs. 6701
Hi ---,
As discussed, we agree with --- that you should always look at all the facts and circumstances to determine whether one or the other or both penalties apply with respect to a particular return or other document, and if both apply, which one to assert. I’ve attached the legislative history I mentioned that indicates that if both penalties apply, the Service can choose which one to assert. See p. 577.
Thanks,
---
---
---