Pursuant to Sections 6055 and 6056 of the Internal Revenue Code (the “Code”), providers of health coverage (insurance companies or self-insured plans) and applicable large employers (“ALEs,” generally those with 50+ full-time or full-time equivalent employees) must file statements with the ...
One useful simplification would be that IRS notices that assess penalties be made to indicate the code section under which the penalty is being assessed. In the original 1954 code, there were only six penalties; today, penalties rival in number the uncountable stars of the heavens and grains ...
In fact, the Code is chock full of penalty provisions. So, a reasonable shortcut to all the detail is to say that taxpayersalwayswant to argue that they acted reasonably and with cause in claiming every single item listed on the tax return in good faith. However, when do taxpayersnotwant...