2010-15, and applies to returns filed on 2010 tax forms for a taxable year beginning in 2010, and to returns filed on 2010 tax forms in 2011 for short taxable years beginning in 2011. The taxpayers filed a Petition in the US Tax Court. IRC 6707A imposes a penalty for failure to include reportable. In addition, the new guidance states that adequate disclosure on Schedule UTP, Uncertain Tax Position Statement, will be treated as equivalent to filing Form 8275, Disclosure Statement, or Form 8275-R, Regulation Disclosure Statement. The 40 penalty was approved on IRS administrative review, but due to an alleged clerical error, the Notice of Deficiency sent to the taxpayers listed only the standard 20 accuracy-related penalty under IRC section 6662(a). IRC 6662A imposes an accuracy-related penalty on a reportable transaction understatement. The new guidance only applies to the disclosure rules with respect to the substantial understatement penalty in IRC § 6662(d) and does not apply to: (i) the disregard of rules and regulations in IRC § 6662(b)(1), (ii) the increased forty percent penalty for failure to disclose a transaction lacking economic substance in IRC § 6662(i), or (iii) the increased forty percent penalty for failure to disclose a foreign financial asset in IRC § 6662(j). If and when employers or businesses fail to pay their trust fund taxes on time, IRC 66722 permits the government to impose the Trust Fund Recovery Penalty. Proc.) 2011-13 updating the requirements for adequate disclosure of an item or position on a taxpayer’s income tax return for purposes of avoiding the substantial understatement penalty under IRC § 6662(d) and for the purpose of avoiding the tax return preparer penalty under IRC § 6694(a), relating to understatements due to unreasonable positions. On December 28, 2010, the IRS issued Revenue Procedure (Rev. Section 6651(a)(3) penalties for failure to pay, negligence penalties under I.R.C. 9 IRS LB&I Directive Exhibit 4.46.4-4 Guidance for Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties. IRS updates adequate disclosure penalty guidance
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