penalty and may a preparer limit the potential penalty amount with respect to a given client by intentionally bifurcating billing into various different engagements?
Notice 2008-13 addresses the interim standards applicable to tax return preparers under Section 6694(a), and was not intended to address other aspects of the return preparer penalty. Final guidance under Section 6694, when issued, will address the standards applicable to tax return preparers under Section 6694, as well as all of the other elements of the return preparer penalty under Section 6694, including the penalty amounts and related calculations. Nevertheless, tax return preparers and their clients should understand that the IRS has significant experience in looking through the form of transactions in determining their true substance, and should expect that all billing arrangements between tax return preparers and their clients will be scrutinized to ascertain the actual substance of those arrangements.
Related Questions
- penalty and may a preparer limit the potential penalty amount with respect to a given client by intentionally bifurcating billing into various different engagements?
- What is the minimum number of consumer accounts for which you will do billing services for a single client?
- What is the income potential for a tax preparer in the first year?
