Hyatt Regency San Francisco 5 Embarcadero Center, San Francisco, California
Richard J. Sapinski
American Bar Association Section of Taxation and Section of Real Property, Trust & Estate Law
The Reasonable Cause Defense: Effective Strategies When Requesting Penalty Abatement
This panel will address the specifics of the reasonable cause defense to challenge penalties asserted by the IRS and discuss the strategic decisions a practitioner should consider with respect to penalty abatement. The panel will focus on domestic penalty issues, but will also touch on some international penalty issues. The panel will consider how a practitioner builds a reasonable cause position, the practical considerations of when to request abatement, and hear from IRS Appeals and the Tax Court as to how each considers and weighs arguments and evidence demonstrating reasonable cause.