For over a decade, we have provided legal advice and developed and presented training to IRS attorneys and IRS revenue agents nationwide regarding civil tax penalties (including civil tax penalties under §§ 6662, 6662A, 6663, 6664, 6676, 6694, 6695A and first-time abatement). Because our practice deals with federal tax issues, we accept clients nationwide. We have significant experience with the requirements regarding reportable transactions (including listed transactions) and Form 8886, “Disclosure Statements,” as well as disclosures on Form 8918 for “Material Advisors.”
If you are concerned about a civil penalty or disclosures, let’s talk.