Foley & Lardner LLP partner Lynn Gandhi examined state standards for penalty abatement in her Tax Notes article, “Challenging Penalties: What Are the Standards?”
In the article, Gandhi details two seemingly unrelated judicial decisions issued in January that upheld penalties against taxpayers, highlighting the inconsistent burdens and challenges taxpayers can face when seeking relief.
“With the increased use of substantial understatement penalties, taxpayers are advised to conduct thorough research in preparing their request for penalty abatement, because, unlike fine wine, penalties don’t improve with age,” she concludes.
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