DOCSLIB.ORG

Bulletin No. 2021–26 June 28, 2021 HIGHLIGHTS of THIS ISSUE

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Bulletin No. 2021–26 June 28, 2021 HIGHLIGHTS of THIS ISSUE HIGHLIGHTS Bulletin No. 2021–26 OF THIS ISSUE June 28, 2021 These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. ADMINISTRATIVE EMPLOYEE PLANS Rev. Proc. 2021-27, page 1252. Notice 2021-37, page 1227. This procedure provides specifications for the private print- This notice sets forth updates on the corporate bond month- ing of red-ink substitutes for the 2021 revisions of certain ly yield curve, the corresponding spot segment rates for information returns. This procedure will be reproduced as June 2021 used under § 417(e)(3)(D), the 24-month average the next revision of Publication 1179. Revenue Procedure segment rates applicable for June 2021, and the 30-year 2020-35 is superseded. Treasury rates, as reflected by the application of § 430(h) (2)(C)(iv). ADMINISTRATIVE; INCOME TAX EMPLOYMENT TAX T.D. 9950, page 1221. These final regulations amend regulations under sections Rev. Proc. 2021-22, page 1231. 165 and 7508A, interpreting new section 7508A(d) relating General Rules and Specifications for Substitute Form 941, to mandatory postponements of time to perform time-sensi- Schedule B (Form 941), Schedule D (Form 941), Schedule R tive tax acts by reason of a federally declared disaster, and (Form 941), and Form 8974. This procedure provides gener- clarifying the definition of federally declared disaster under al rules and specifications from the IRS for paper and com- section 165(i)(5). The final regulations clarify that the phrase puter-generated substitutes for Form 941; Schedule B (Form “in the same manner as a period specified under [section 941); Schedule D (Form 941); Schedule R (Form 941); and 7508A(a)]” in section 7508A(d)(1) means that the time-sen- Form 8974. This procedure supersedes Revenue Procedure sitive acts postponed for the mandatory 60-day period are 2020-31, 2020-27 I.R.B. 12. those determined by the Secretary under section 7508A(a). The final regulations further provide that the mandatory 60- INCOME TAX day period will only apply if the Secretary bases her discre- tionary determination on a disaster declaration that specifies an incident date. The final regulations also clarify that the Notice 2021-36, page 1227. mandatory 60-day period cannot exceed the one-year limita- This Notice announces that the Treasury Department and the tion provided under section 7508A(a). Finally, the final regu- IRS intend to amend the regulations under sections 59A and lations clarify that a federally declared disaster includes an 6038A to defer the applicability date of certain provisions of event declared either a major disaster under section 401 of the regulations relating to the reporting of qualified derivative the Stafford Act or an emergency under section 501 of the payments until taxable years beginning on or after January Stafford Act. 1, 2023. Finding Lists begin on page ii. The IRS Mission Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and en- force the law with integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument against reaching the same conclusions in other cases unless of the Commissioner of Internal Revenue for announcing of- the facts and circumstances are substantially the same. ficial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of The Bulletin is divided into four parts as follows: general interest. It is published weekly. Part I.—1986 Code. It is the policy of the Service to publish in the Bulletin all sub- This part includes rulings and decisions based on provisions stantive rulings necessary to promote a uniform application of the Internal Revenue Code of 1986. of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- Part II.—Treaties and Tax Legislation. wise indicated. Procedures relating solely to matters of inter- This part is divided into two subparts as follows: Subpart A, nal management are not published; however, statements of Tax Conventions and Other Related Items, and Subpart B, internal practices and procedures that affect the rights and Legislation and Related Committee Reports. duties of taxpayers are published. Part III.—Administrative, Procedural, and Miscellaneous. Revenue rulings represent the conclusions of the Service To the extent practicable, pertinent cross references to these on the application of the law to the pivotal facts stated in subjects are contained in the other Parts and Subparts. Also the revenue ruling. In those based on positions taken in rul- included in this part are Bank Secrecy Act Administrative ings to taxpayers or technical advice to Service field offices, Rulings. Bank Secrecy Act Administrative Rulings are issued identifying details and information of a confidential nature are by the Department of the Treasury’s Office of the Assistant deleted to prevent unwarranted invasions of privacy and to Secretary (Enforcement). comply with statutory requirements. Part IV.—Items of General Interest. Rulings and procedures reported in the Bulletin do not have the This part includes notices of proposed rulemakings, disbar- force and effect of Treasury Department Regulations, but they ment and suspension lists, and announcements. may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and The last Bulletin for each month includes a cumulative index procedures, the effect of subsequent legislation, regulations, for the matters published during the preceding months. These court decisions, rulings, and procedures must be considered, monthly indexes are cumulated on a semiannual basis, and are and Service personnel and others concerned are cautioned published in the last Bulletin of each semiannual period. The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. June 28, 2021 Bulletin No. 2021–26 Part I 26 CFR 301.7508A-1: Postponement of certain FOR FURTHER INFORMATION ple (3), in these final regulations to better tax-related deadlines by reasons of a federally CONTACT: Andrew C. Keaton at (202) illustrate the calculation of the mandatory declared disaster or terroristic or military action; 26 CFR 1.165-1: Losses 317-5404 (not a toll-free number). 60-day postponement period and to cor- rect typographical errors. No other chang- T.D. 9950 SUPPLEMENTARY INFORMATION: es have been adopted. Background Comments on the Proposed DEPARTMENT OF THE Regulations TREASURY Section 205 of the Taxpayer Certainty and Disaster Tax Relief Act of 2019, en- Section 1.165-11(b)(1) Internal Revenue Service acted as Division Q of the Further Con- 26 CFR Parts 1 and 301 solidated Appropriations Act, 2020, Pub- The proposed regulations provided that lic Law 116-94, 133 Stat. 2534, 3226, a federally declared disaster includes both Mandatory 60-Day amended section 7508A of the Code, re- a major disaster and an emergency de- lating to the discretionary authority of the clared under sections 401 or 501, respec- Postponement of Certain Secretary of the Treasury or her delegate tively, of the Robert T. Stafford Disaster Tax-Related Deadlines (Secretary) to postpone certain time-sen- Relief and Emergency Assistance Act by Reason of a Federally sitive tax deadlines by reason of a feder- (Stafford Act), Public Law 100-707,102 Declared Disaster ally declared disaster, by adding section Stat. 4689 (1988). 7508A(d). This provision provides qual- One commenter said it approved of ified taxpayers a mandatory 60-day peri- the proposed regulations including emer- AGENCY: Internal Revenue Service od that is to be disregarded “in the same gency declarations in the definition of a (IRS), Treasury. manner as a period specified under [sec- federally declared disaster under section tion 7508A(a)].” 165(i)(5)(A). However, another comment- ACTION: Final regulations. On January 13, 2021, the IRS pub- er was critical of this portion of the pro- lished in the Federal Register a notice of posed regulations and recommended that SUMMARY: This document contains final proposed rulemaking (REG-115057-20, it be stricken. This second commenter said regulations relating to the new mandatory 86 FR 2607) to interpret and implement emergency declarations are governed by a 60-day postponement of certain time-sen- sections 165(i)(5) and 7508A(d). Five re- different set of rules than major disaster sitive tax-related deadlines by reason of a sponsive written comments were received. declarations, pointing out that emergency federally declared disaster. This document No commenter requested a public hearing, declarations (i) do not need to be preceded also contains final regulations clarifying so none was held. by a governor’s request for Stafford Act the definition of “federally declared disas- As described more fully in the pream- relief (but may instead be declared sua ter.” These final regulations affect individ- ble to the proposed regulations, section sponte by the President), (ii) may only re- uals who reside in or were killed or injured 7508A(d) is ambiguous in at least two im- sult (if not followed up by a major disaster in a disaster area, businesses that have a portant respects – the time-sensitive acts to declaration) in Federal assistance to local principal place of business in a disaster be postponed (beyond the pension-related governmental entities (as opposed to as- area, relief workers who provide assistance actions described in section 7508A(d)(4)) sistance to individuals), and (iii) may be in a disaster area, or any taxpayer whose are not specified and it is unclear how the issued before a disaster.
Load more

Recommended publications
  • Form W-4, Employee's Withholding Certificate
    Employee’s Withholding Certificate OMB No. 1545-0074 Form W-4 ▶ (Rev. December 2020) Complete Form W-4 so that your employer can withhold the correct federal income tax from your pay. ▶ Department of the Treasury Give Form W-4 to your employer. 2021 Internal Revenue Service ▶ Your withholding is subject to review by the IRS. Step 1: (a) First name and middle initial Last name (b) Social security number Enter Address ▶ Does your name match the Personal name on your social security card? If not, to ensure you get Information City or town, state, and ZIP code credit for your earnings, contact SSA at 800-772-1213 or go to www.ssa.gov. (c) Single or Married filing separately Married filing jointly or Qualifying widow(er) Head of household (Check only if you’re unmarried and pay more than half the costs of keeping up a home for yourself and a qualifying individual.) Complete Steps 2–4 ONLY if they apply to you; otherwise, skip to Step 5. See page 2 for more information on each step, who can claim exemption from withholding, when to use the estimator at www.irs.gov/W4App, and privacy. Step 2: Complete this step if you (1) hold more than one job at a time, or (2) are married filing jointly and your spouse Multiple Jobs also works. The correct amount of withholding depends on income earned from all of these jobs. or Spouse Do only one of the following. Works (a) Use the estimator at www.irs.gov/W4App for most accurate withholding for this step (and Steps 3–4); or (b) Use the Multiple Jobs Worksheet on page 3 and enter the result in Step 4(c) below for roughly accurate withholding; or (c) If there are only two jobs total, you may check this box.
    [Show full text]
  • The Alternative Minimum Tax
    Updated December 4, 2017 Tax Reform: The Alternative Minimum Tax The U.S. federal income tax has both a personal and a Individual AMT corporate alternative minimum tax (AMT). Both the The modern individual AMT originated with the Revenue corporate and individual AMTs operate alongside the Act of 1978 (P.L. 95-600) and operated in tandem with an regular income tax. They require taxpayers to calculate existing add-on minimum tax prior to its repeal in 1982. their liability twice—once under the rules for the regular Table 2 details selected key individual AMT parameters. income tax and once under the AMT rules—and then pay the higher amount. Minimum taxes increase tax payments Table 2. Selected Individual AMT Parameters, 2017 from taxpayers who, under the rules of the regular tax system, pay too little tax relative to a standard measure of Single/ Married their income. Head of Filing Married Filing Household Jointly Separately Corporate AMT Exemption $54,300 $84,500 $42,250 The corporate AMT originated with the Tax Reform Act of 1986 (P.L. 99-514), which eliminated an “add-on” 28% bracket 187,800 187,800 93,900 minimum tax imposed on corporations previously. The threshold corporate AMT is a flat 20% tax imposed on a Source: Internal Revenue Code. corporation’s alternative minimum taxable income less an exemption amount. A corporation’s alternative minimum The individual AMT tax base is broader than the regular taxable income is the corporation’s taxable income income tax base and starts with regular taxable income and determined with certain adjustments (primarily related to adds back various deductions, including personal depreciation) and increased by the disallowance of a exemptions and the deduction for state and local taxes.
    [Show full text]
  • Form 211, Application for Award for Original Information
    Department of the Treasury - Internal Revenue Service OMB Number 1545-0409 Form 211 Application for Award for Date Claim received (July 2018) Claim number (completed by IRS) Original Information Section A – Information About the Person or Business You Are Reporting 1. Is this New submission or Supplemental submission 2. Last 4 digits of Taxpayer Identification If a supplemental submission, list previously assigned claim number(s) Number(s) (e.g., SSN, ITIN, or EIN) 3. Name of taxpayer (include aliases) and any related taxpayers who committed the violation 4. Taxpayer's address, including ZIP code 5. Taxpayer's date of birth or approximate age 6. Name and title and contact information of IRS employee to whom violation was first reported, if known 7. Alleged Violation of Tax Law (check all that apply) Income Tax Employment Tax Estate & Gift Tax Tax Exempt Bonds Employee Plans Governmental Entities Exempt Organizations Excise Other (identify) 8. Describe the Alleged Violation. State all pertinent facts to the alleged violation. (Attach a detailed explanation and include all supporting information in your possession and describe the availability and location of any additional supporting information not in your possession.) Explain why you believe the act described constitutes a violation of the tax laws 9. Describe how you learned about and/or obtained the information that supports this claim. (Attach sheet if needed) 10. What is your relationship (current and former) to the alleged noncompliant taxpayer(s)? Check all that apply. (Attach sheet if needed) Current Employee Former Employee Attorney CPA Relative/Family Member Other (describe) 11. Do you still maintain a relationship with the taxpayer Yes No 12.
    [Show full text]
  • 2021 Instructions for Form 6251
    Note: The draft you are looking for begins on the next page. Caution: DRAFT—NOT FOR FILING This is an early release draft of an IRS tax form, instructions, or publication, which the IRS is providing for your information. Do not file draft forms and do not rely on draft forms, instructions, and publications for filing. We do not release draft forms until we believe we have incorporated all changes (except when explicitly stated on this coversheet). However, unexpected issues occasionally arise, or legislation is passed—in this case, we will post a new draft of the form to alert users that changes were made to the previously posted draft. Thus, there are never any changes to the last posted draft of a form and the final revision of the form. Forms and instructions generally are subject to OMB approval before they can be officially released, so we post only drafts of them until they are approved. Drafts of instructions and publications usually have some changes before their final release. Early release drafts are at IRS.gov/DraftForms and remain there after the final release is posted at IRS.gov/LatestForms. All information about all forms, instructions, and pubs is at IRS.gov/Forms. Almost every form and publication has a page on IRS.gov with a friendly shortcut. For example, the Form 1040 page is at IRS.gov/Form1040; the Pub. 501 page is at IRS.gov/Pub501; the Form W-4 page is at IRS.gov/W4; and the Schedule A (Form 1040/SR) page is at IRS.gov/ScheduleA.
    [Show full text]
  • The Viability of the Fair Tax
    The Fair Tax 1 Running head: THE FAIR TAX The Viability of The Fair Tax Jonathan Clark A Senior Thesis submitted in partial fulfillment of the requirements for graduation in the Honors Program Liberty University Fall 2008 The Fair Tax 2 Acceptance of Senior Honors Thesis This Senior Honors Thesis is accepted in partial fulfillment of the requirements for graduation from the Honors Program of Liberty University. ______________________________ Gene Sullivan, Ph.D. Thesis Chair ______________________________ Donald Fowler, Th.D. Committee Member ______________________________ JoAnn Gilmore, M.B.A. Committee Member ______________________________ James Nutter, D.A. Honors Director ______________________________ Date The Fair Tax 3 Abstract This thesis begins by investigating the current system of federal taxation in the United States and examining the flaws within the system. It will then deal with a proposal put forth to reform the current tax system, namely the Fair Tax. The Fair Tax will be examined in great depth and all aspects of it will be explained. The objective of this paper is to determine if the Fair Tax is a viable solution for fundamental tax reform in America. Both advantages and disadvantages of the Fair Tax will objectively be pointed out and an educated opinion will be given regarding its feasibility. The Fair Tax 4 The Viability of the Fair Tax In 1986 the United States federal tax code was changed dramatically in hopes of simplifying the previous tax code. Since that time the code has undergone various changes that now leave Americans with over 60,000 pages of tax code, rules, and rulings that even the most adept tax professionals do not understand.
    [Show full text]
  • Form 1040 Page Is at IRS.Gov/Form1040; the Pub
    Note: The draft you are looking for begins on the next page. Caution: DRAFT—NOT FOR FILING This is an early release draft of an IRS tax form, instructions, or publication, which the IRS is providing for your information. Do not file draft forms and do not rely on draft forms, instructions, and publications for filing. We do not release draft forms until we believe we have incorporated all changes (except when explicitly stated on this coversheet). However, unexpected issues occasionally arise, or legislation is passed—in this case, we will post a new draft of the form to alert users that changes were made to the previously posted draft. Thus, there are never any changes to the last posted draft of a form and the final revision of the form. Forms and instructions generally are subject to OMB approval before they can be officially released, so we post only drafts of them until they are approved. Drafts of instructions and publications usually have some changes before their final release. Early release drafts are at IRS.gov/DraftForms and remain there after the final release is posted at IRS.gov/LatestForms. All information about all forms, instructions, and pubs is at IRS.gov/Forms. Almost every form and publication has a page on IRS.gov with a friendly shortcut. For example, the Form 1040 page is at IRS.gov/Form1040; the Pub. 501 page is at IRS.gov/Pub501; the Form W-4 page is at IRS.gov/W4; and the Schedule A (Form 1040/SR) page is at IRS.gov/ScheduleA.
    [Show full text]
  • [REG-107100-00] RIN 1545-AY26 Disallowance of De
    [4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG-107100-00] RIN 1545-AY26 Disallowance of Deductions and Credits for Failure to File Timely Return AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing. SUMMARY: This document contains proposed regulations relating to the disallowance of deductions and credits for nonresident alien individuals and foreign corporations that fail to file a timely U.S. income tax return. The current regulations permit nonresident aliens and foreign corporations the benefit of deductions and credits only if they timely file a U.S. income tax return in accordance with subtitle F of the Internal Revenue Code, unless the Commissioner waives the filing deadlines. The temporary regulations revise the waiver standard. The text of the temporary regulations on this subject in this issue of the Federal Register also serves as the text of these proposed regulations set forth in this cross-referenced notice of proposed rulemaking. This document also provides notice of a public hearing on these proposed regulations. DATES: Written comments must be received by April 29, 2002. Requests to speak and outlines of topics to be discussed at the public hearing scheduled for June 3, 2002, at 10 a.m. must be received by May 13, 2002. ADDRESSES: Send submissions to: CC:ITA:RU (REG-107100-00), room 5226, Internal -2- Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand delivered Monday through Friday between the hours of 8 a.m.
    [Show full text]
  • 2021 Form 1099-MISC
    Attention: Copy A of this form is provided for informational purposes only. Copy A appears in red, similar to the official IRS form. The official printed version of Copy A of this IRS form is scannable, but the online version of it, printed from this website, is not. Do not print and file copy A downloaded from this website; a penalty may be imposed for filing with the IRS information return forms that can’t be scanned. See part O in the current General Instructions for Certain Information Returns, available at www.irs.gov/form1099, for more information about penalties. Please note that Copy B and other copies of this form, which appear in black, may be downloaded and printed and used to satisfy the requirement to provide the information to the recipient. To order official IRS information returns, which include a scannable Copy A for filing with the IRS and all other applicable copies of the form, visit www.IRS.gov/orderforms. Click on Employer and Information Returns, and we’ll mail you the forms you request and their instructions, as well as any publications you may order. Information returns may also be filed electronically using the IRS Filing Information Returns Electronically (FIRE) system (visit www.IRS.gov/FIRE) or the IRS Affordable Care Act Information Returns (AIR) program (visit www.IRS.gov/AIR). See IRS Publications 1141, 1167, and 1179 for more information about printing these tax forms. 9595 VOID CORRECTED PAYER’S name, street address, city or town, state or province, country, ZIP 1 Rents OMB No.
    [Show full text]
  • Federal Register/Vol. 68, No. 208/Tuesday, October 28, 2003
    61552 Federal Register / Vol. 68, No. 208 / Tuesday, October 28, 2003 / Notices interest and redemption payments. The Information concerning book-entry Board of Governors of the Federal Treasury currently absorbs these costs transfers of government agency Reserve System [Docket OP–1165]. and will continue to do so. securities, which are priced by the The following is the Treasury fee The fees described in this notice Federal Reserve System, is set out in a schedule that will take effect on January apply only to the transfer of Treasury separate Federal Register notice 2, 2004, for the book-entry transfers on book-entry securities held on NBES. published elsewhere in this issue by the NBES: TREASURY—NBES FEE SCHEDULE 1 [Effective January 2, 2004, (in dollars)] Funds 2 Transfer type Basic fee Off-line move- Total fee surcharge ment fee On-line transfer originated ............................................................................................................... .21 .00 .04 .25 On-line transfer received ................................................................................................................. .21 .00 .04 .25 On-line reversal transfer originated ................................................................................................. .21 .00 .04 .25 On-line reversal transfer received ................................................................................................... .21 .00 .04 .25 Off-line transfer originated ..............................................................................................................
    [Show full text]
  • Taxpayer Identification Number Certification Instructions
    TAXPAYER IDENTIFICATION NUMBER CERTIFICATION INSTRUCTIONS (Section references are to the Internal Revenue Code.) 1. PURPOSE OF FORM A credit union that is required to file information returns with the Internal Revenue Service (IRS) must get the correct taxpayer identification numbers (TINs) of members in order to report to the IRS certain income paid to members (A TIN is either a social security number (SSN), an employee identification number (EIN), or an individual tax identification number (ITIN).) IRS Form W-9, Request for Taxpayer Identification Number and Certification, is used by credit unions to request correct TINs for members as well as to request that members certify certain claims. Form W-9 is used if members can certify that they are U.S. persons or resident aliens, that the TINs they provide are correct, and that they are not subject to backup withholding. Use Form W-9, Request For Taxpayer Identification Number And Certification or Credit Union’s qualifying signature card form to furnish your correct TIN to the requester (the person asking you to furnish your TIN), and, when applicable (1) to certify that the TIN you are furnishing is correct (or that you are waiting for a number to be issued, (2) to certify that you are not subject to backup withholding, and (3) to claim exemption from backup withholding if you are an exempt payee. Furnishing your correct TIN and making the appropriate certifications will prevent certain payments from being subject to the 28% backup withholding. Individuals who have an ITIN must provide it on Form W-9.
    [Show full text]
  • [4830-01-U] DEPARTMENT of THE
    [4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 31 [TD 8822] RIN 1545-AW28 Federal Employment Tax Deposits-De Minimis Rule AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document contains final regulations relating to the deposit of Federal employment taxes. The final regulations adopt the rules of temporary regulations that change the de minimis deposit rule for quarterly and annual return periods from $500 to $1,000. The regulations affect taxpayers required to make deposits of Federal employment taxes. DATES: Effective date: These regulations are effective June 17, 1999. Applicability date: For dates of applicability, see §31.6302-1(f)(4). FOR FURTHER INFORMATION CONTACT: Vincent Surabian, (202) 622- 4940 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background This document contains amendments to 26 CFR part 31, Employment Taxes and Collection of Income Tax at Source. On June 16, 1998, temporary and final regulations (TD 8771) relating to the deposit of Federal employment taxes under section 6302 of the - 2 - Internal Revenue Code were published in the Federal Register (63 FR 32735). A notice of proposed rulemaking (REG-110403-98) cross-referencing the temporary regulations was published in the Federal Register for the same day (63 FR 32774). No comments were received from the public in response to the notice of proposed rulemaking. Explanation of Provisions These final regulations adopt the rules of the temporary regulations. Under these rules, a taxpayer that has accumulated Federal employment taxes of less than $1,000 for a return period (quarterly or annual, as the case may be) does not have to make deposits but may remit its full liability with a timely filed return for the return period.
    [Show full text]
  • Revenge of the Tax Protesters
    G THE B IN EN V C R H E S A N 8 D 8 B 8 A E 1 R SINC Web address: http://www.nylj.com VOLUME 234—NO. 52 WEDNESDAY, SEPTEMBER 14, 2005 TAX LITIGATION ISSUES BY JOHN J. TIGUE JR. AND JEREMY H. TEMKIN Revenge of the Tax Protesters ax protesters, or individuals noted that courts “have consistently who claim that they are not rejected …arguments [raised by tax legally required to pay taxes, protesters] and imposed substantial penal- have been around for a long ties on those taking these unsupportable T positions. Those potentially tempted by time. In recent years, however, the num- ber of tax protesters appears to have these schemes need to realize that they increased as numerous individuals and carry a heavy price for both the taxpayers 2 groups actively market and sell a variety of John J. Tigue Jr. Jeremy H. Temkin and the promoters.” As set forth in IRS materials supporting the claim that Notice 2005-30, civil and criminal American citizens are not obligated to pay penalties apply to taxpayers who make income taxes. As a result, the IRS has increased its frivolous arguments. Civil penalties Among the arguments raised by tax focus on prosecuting individuals who include a $500 penalty for filing a protesters are: (1) that the 16th make such arguments, which it views as frivolous income tax return and a penalty Amendment to the Constitution, which willful tax evasion. In March of this year, of up to $25,000 if a taxpayer pursues authorizes income taxes, was never IRS Commissioner Mark W.
    [Show full text]