Review of Internal Revenue Code Penalties: Hearing Before the Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, One Hundredth Congress, Second Session, March 14, 1988, Volume 4

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Page 226 - is the omission to do something which a reasonable man, guided by those considerations which ordinarily regulate the conduct of human affairs, would do, or doing something which a prudent and reasonable man would not do.* 1 The
Page 137 - ...[although] many controversies have raged about the cryptic and abstract words of the Due Process Clause, there can be no doubt that at a minimum they require that deprivation of life, liberty, or property by adjudication be preceded by notice and opportunity for hearing appropriate to the nature of the case." (Mullane v. Central Hanover Trust Co.. 339 US 306,
Page 167 - There have been five major tax bills in this decade alone—the Economic Recovery Tax Act of 1981, the Tax Equity and Fiscal Responsibility Act of 1982, the Tax Reform Act of 1984, the Tax Reform Act of 1986, and the Revenue Act of 1987. These bills enacted
Page 60 - Aiding and abetting the understatement of tax liability 25 .—The Code imposes a penalty on any person who aids, assists in, procures, or advises with respect to the preparation or presentation of any portion of a return or other document under the internal revenue laws which the person knows will be used in
Page 3 - Washington, DC.—Senator David Pryor, (D., Arkansas), Chairman of the Senate Finance Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service, announced Wednesday that the Subcommittee will hold a hearing to review Internal Revenue Code
Page 55 - 8 A special rule governs items "attributable to a tax shelter," meaning a partnership or other entity, plan or arrangement, the principal purpose of which is the avoidance or evasion of Federal income tax. In the case of such a tax shelter item, adequate disclosure on the return will
Page 223 - any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof
Page 145 - the case of an individual who is paid or receives all of his wages, salary, and other income on a weekly basis, the amount of the wages, salary, and other income payable to or received by him during any week which is exempt from levy under subsection (a)(9) shall be
Page 153 - of collecting the proper amount of tax revenue, at the least cost to the public, and in a manner that warrants the highest degree of public confidence in our integrity, efficiency and fairness. to
Page 205 - is attributable to an officer or employee being dilatory in performing a ministerial act. An error or delay Is taken into account only If no significant aspect of such error or delay can be attributed to the taxpayer Involved. However, the definition of a ministerial act by the

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