Miscellaneous Issues

ID:
UILC:
CCA_2016060711430306
9999.00-00
Number: 201637015
Release Date: 9/9/2016
From:
Sent: Tuesday, June 07, 2016 11:43:03 AM
To:
Cc:
Bcc:
Subject: FW: Form 8928 Referrals
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As we discussed during our phone call on June 3, 2016 concerning ---
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The Form 8928 instructions (page 4) provide that the Secretary may waive part or all of the excise tax under Part II, to the extent that payment of the tax would be excessive relative to the failure involved. This only applies to failures due to reasonable cause and not due to willful neglect. We believe the waiver is appropriate under the circumstances involved in this matter.
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