I was perusing the IRS website and came across this in the Internal Revenue Manual: 1.4.53.5 (08-20-2010) Protecting Taxpayer Rights A primary responsibility of managers must be to monitor employee practices and actions to ensure that taxpayer rights are always observed during our efforts to bring taxpayers into compliance. Taxpayer rights include, but are not [...]

Internal Revenue Manual 8.22.2.2.12.2 (10-30-2007) Section 6702 Frivolous Return Penalties and Questionable W-4 Penalties 1. Frivolous Return Penalties and questionable W-4 penalties do not receive a notice that gives the taxpayer an opportunity to go to Appeals. Therefore, issues involving these penalties may be raised in CDP. 2. A taxpayer may challenge the assessment of [...]