Daily Tax Update - December 15, 2008

IRS ISSUES ADDITIONAL GUIDANCE RELATED TO PREPARER PENALTIES: Today, the IRS issued additional guidance related to the final rules (T.D. 9436) on tax return preparer penalties.

  • Notice 2009-5 provides guidance regarding implementation of the tax return prepare penalty under tax code Section 6694(a). The service is also requesting comments on the interim guidelines in this notice.
  • Rev. Proc. 2009-11 describes the returns and claims for refund that are subject to the penalties for understatement of a taxpayer's liability by a tax return preparer under Section 6694 and for the tax return preparer's failure to sign the return or claim for refund under Section 6694(b).
  • Additional information can be accessed via:

INTERNAL REVENUE SERVICE - CIRCULAR 230 DISCLOSURE:
As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this communication (including attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any plan or arrangement addressed herein.

STEPTOE & JOHNSON LLP - TAX PRACTICE
Steptoe & Johnson LLP has one of the largest and most diverse law firm tax practices in the country. The practice covers the entire spectrum of federal taxation, including representation of businesses before the Congress, Treasury and the national office of the IRS; transactional planning for domestic and multinational corporations; complex audit and controversy work for corporations and other business interests contesting IRS adjustments; litigation before the Tax Court, Court of Federal Claims, district courts, courts of appeals and the Supreme Court. The firm's tax practice also encompasses all aspects of employee benefits (ERISA), executive compensation, tax-exempt organizations and charitable giving. Steptoe has an extensive state and local tax practice, representing an array of business clients on complex sales and use tax, corporate income tax and property tax matters, both advising those clients and handling audits, administrative appeals, and litigation for them. Read more information on Steptoe's tax practice.