Recent decisions have provided taxpayers with new ways to procedurally challenge penalties assessed in their cases. Joshua D. Smeltzer, former Department of Justice Tax Division litigator now at Gray Reed, recently published an article in the Journal of Tax Practice & Procedure (a quarterly scholarly journal published by CCH Inc.) outlining the questions that taxpayer and their advisors should be asking when they are assessed penalties by the IRS. A reprint of the article is available here.
