Section 6700 Penalties – Issues and Unique Procedural Hurdles

Under Section 6700 of the Internal Revenue Code, the IRS can assess penalties for promoting an “abusive tax shelter.” The general application of the penalty (as well as discussion of a relevant Chief Counsel Advice memorandum) was discussed in a previous Freeman Law blog: https://freemanlaw.com/section-6700-penalties-false-or-fraudulent-statements/.... By: Freeman Law