Defensive Tax Return Disclosures
Defensive tax return disclosures are made on Forms 8275 or 8275R, depending on whether the declared position is consistent or inconsistent with extant treasury regulations. However, the reason for filing defensive tax return disclosures goes beyond avoiding penalties associated with intentional disregard for rules and regulations. Preempting IRS deficiency notice presumptive correctness is a dominating consideration. This webcast explains.
Forms 8725 and 8725R and Intentional Disregard of Rules and Regulation Penalties
Affirmative Equitable Defenses
Preempting IRS Deficiency Notice Presumptive Correctness
**Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to email@example.com.
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