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Tom Cullinan and Erin Hines article “A primer on IRS tax avoidance promoter penalties,” in Accounting Today
In an article published in Accounting Today on March 22, 2024, Atlanta-based Shareholder Tom Cullinan and Senior Counsel Erin Hines discussed IRS penalties on “promoters” of tax avoidance transactions. The article reviews potential penalties and makes suggestions for those dealing with a promoter audit.
“In responding to a promoter investigation, you want to be responsive and cooperative while also juggling the invasive and costly nature of the investigation. Cabining the scope, or limiting or restricting the extent of the investigation, if possible, is one way to achieve those goals,” Cullinan and Hines wrote.
“While lengthy audits might favor the alleged promoter in some cases, seeking a quick and acceptable resolution can mitigate risk. Of course, that is not always possible, and in some cases the IRS and DOJ will be unrelenting in their pursuit of penalties. Unfortunately, the best strategy in such cases usually calls for intense litigation which, while expensive, can be productive.”
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