I’m not blogging a lot on these cases at the moment because the IRS has — yet again — changed its procedures. And I don’t want to talk about things too much for fear of screwing things up for our clients.
But. . . .
After a year of the IRS changing its procedures repeatedly, taking hard lines on penalties, and telling taxpayers to go get bent and take the “20% of high balance” penalty and be happy (yes, the beatings will continue until morale improves), the IRS finally realized that FAQ #35 exists.
It is theoretically possible to settle cases on a basis other than the “20% of high balance” penalty.
And we’ve closed cases along those lines.
I say this because if there are any of you out there who are in the amnesty and you’re getting hammered to accept the 20% of high balance penalty, don’t roll over and play dead. Push hard.
Here’s your recipe manual — for the self-represented folks out there.
Please note that there are variations on this theme depending on which IRS office is handling the case. As the saying goes, the future’s already here, it’s just not evenly distributed. What’s happening in one office may not be happening in another.