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IRS Not Authorized to Assess Interest, Penalties on Restitution Award (Klein, TC)

The IRS was not authorized under Code Sec. 6201(a)(4) to add underpayment interest or failure-to-pay penalties to a criminal restitution award. In addition, the IRS was not allowed to assess or collect underpayment interest or additions to tax without first determining the taxpayers’ civil tax liabilities. Background The taxpayers, a married couple, pleaded guilty to […]

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