Chapter 13

In tax practice context, a fine or other judgment that is brought against a taxpayer or preparer for a failure to comply with one or more of the elements of the federal tax law. Examples include ... for failure to file a return or pay a tax in a timely fashion.

Additions to tax based on a percentage of the delinquent tax.

Penalties expressed as a flat dollar amount rather than a percentage of the delinquent tax.

A means by which a taxpayer or preparer can be excused from an applicable penalty or other sanction. For instance, if the taxpayer failed to file a tax return on a timely basis because of illness or if the underlying records were destroyed by natural cause, the taxpayer likely would be excused from the penalty (but not from the tax or any related interest) because of this ... ....

In a federal tax context, a (nonwillful) failure to exercise one's duty with respect to the Internal Revenue Code or to use a reasonable degree of expected or professional care. Examples include the unacceptable failure to attempt to follow the IRS's rules and regulations in the preparation of a tax return for compensation.

In a tax practice context, a taxpayer's action to evade the assessment of a tax. Criminal ... requires a willful intent by the taxpayer. The IRS bears the burden of proof relative to ... allegations.

A ... imposed on taxpayers who ... to ... a required tax return. The ... can be waived for reasonable cause and is coordinated with the ...-...-... ....

A conscious, intentional failure or reckless indifference. Many IRS penalties may be abated if the underlying act resulted from reasonable cause rather than ... ....

A ... imposed on taxpayers who fail to pay a tax that is shown on their return. The ... is generally 0.5% of the required liability for each month that the tax is not paid, up to a maximum ... of 25%.

A civil tax ... assessed in situations in which the taxpayer has been negligent in completing the return or is found to have acted with a disregard of IRS rules and regulations or in which a substantial understatement of the income tax, a substantial valuation or pension-liability overstatement, or a substantial transfer-tax-valuation understatement exists. A 20% ... usually applies to the pertinent understatement, and related interest accrues from the due date of the return, rather than the date on which the ... was assessed.

A taxpayer ... may be incurred if a tax return position is taken and not disclosed to the IRS and no substantial authority (generally, statute, regulation, court decision, or written determination) supports the position.

A return that does not include enough information to figure the correct tax, contains information or statements that on their face indicate that the self-assessment requirement has not been met, or takes positions that are meant to impede the administration of the tax law.

The punishment for a severe infraction of the elements of the federal tax law by a taxpayer or tax preparer. Felony or misdemeanor status for tax crimes can be accompanied by substantial fines or jail terms. Examples of tax crimes include tax evasion and other willful failures to comply with the Internal Revenue Code.

... ... may request relief from joint and several liability if the nonrequesting spouse or former spouse failed to report income, reported income improperly, or claimed improper deductions or credits.

... ... ... ... means that each taxpayer is legally responsible for the entire tax, including any interest and penalties assessed on a jointly filed return.

Is any person who prepares for compensation, or employs one or more persons to prepare for compensation, all or a substantial portion of a tax return or a claim for income tax refund.

A series of fines and other levies by which the IRS encourages taxpayers and preparers to fulfill their responsibilities under the Internal Revenue Code. Examples include penalties for failure to sign returns, keep or furnish copies of returns, and provide required information to federal agencies.

The action by which the IRS or a court prevents (enjoins) a taxpayer, preparer, or tax shelter distributor from undertaking a specified action (e.g., preparing tax returns for compensation or offering a tax shelter for sale).