Review of the Civil Penalty Provisions Contained in the Internal Revenue Code: Hearings Before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, One Hundred First Congress, First Session on Recommendations for Civil Tax Penalty Reform and H.R. 2528 ... February 21 and June 6, 1989
U.S. Government Printing Office, 1989 - Internal revenue law - 423 pages
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addition administrative amended amount apply appropriate believe better bill Chairman PICKLE changes civil claim Code Commissioner Committee compliance comply concern conduct consider correct Court deposit determine disclose disclosure due diligence effective effort existing fact failed failure fraud fund going IMPACT important imposed improve income increase information reporting information returns Institute interest Internal Revenue Internal Revenue Code issues Judge legislation liability litigation means negligence payee payors penalty percent person portion position possible practice practitioner preparer present problems proposed question reasonable recommendations reform regulations relating representatives respect response result rules sanctions shelter specific standard statement structure Subcommittee substantial authority suggest Task Force Tax Court tax law tax penalty tax return taxpayer Thank underpayment valuation
Page 105 - ... well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law, and that it is not interposed for any improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation.
Page 174 - Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed In terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1954.
Page 106 - ... shall impose upon the person who signed it, a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of the reasonable expenses incurred because of the filing of the pleading, motion, or other paper, including a reasonable attorney's fee.
Page 105 - The signature of an attorney or party constitutes a certificate by him that he has read the pleading, motion, or other paper; that to the best of his knowledge, information, and belief formed after reasonable inquiry it is well grounded in fact and is warranted by existing law or a good faith argument for the extension, modification, or reversal of existing law...
Page 253 - Whenever It appears to the Tax Court that proceedings before It have been Instituted by the taxpayer merely for delay, damages in an amount not in excess of $500 shall be awarded to the United States by the Tax Court in its decision.
Page 231 - understatement" of income tax is the excess of the tax required to be shown on the return, over the tax shown on the return (reduced by any rebates of tax).
Page 4 - September 15, 1988, beginning at 9:30 am, in the main Committee hearing room, 1100 Longworth House Office Building. The Subcommittee will receive testimony from the US General Accounting Office and the Financial Accounting Standards Board.
Page 106 - Any attorney or other person admitted to conduct cases in any court of the United States or any Territory thereof who so multiplies the proceedings in any case as to increase costs unreasonably and vexatiously may be required by the court to satisfy personally such excess costs.
Page 392 - NFIB is the nation's largest small business advocacy organization, representing more than 600,000 small business owners in all 50 states and the District of Columbia.
Page 227 - The subcommittee believes that this modification increases the fairness of this component of the accuracy-related penalty, in that the penalty is imposed upon proscribed behavior, regardless of who engages in it. Second, a substantial valuation overstatement exists if the value or adjusted basis of any property claimed on a return is 200 percent or more of the correct value or adjusted basis. Third, the penalty is to apply only if the amount of the underpayment attributable to a valuation overstatement...