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When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

By Bryan C. Skarlatos & Henry Stow Lovejoy
Journal of Tax Practice & Procedure
June – July 2017 Edition

Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining whether a taxpayer acted with reasonable cause and good faith is the taxpayer’s effort to assess the proper tax liability.

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