Did You Get Hit with a Frivolous Return Penalty?
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 the [...]
February 28th, 2009 by admin
