IRS Penalty Defense
IRS penalties can add substantially to a tax dispute, and in some cases they exceed the tax itself. Stone Tax Counsel represents clients in contesting IRS penalties at every stage, from the audit through Appeals and the Tax Court.
Matters We Handle
Underreporting and accuracy penalties
Valuation penalties in charitable contribution and estate and gift cases
Foreign reporting penalties for accounts, companies, trusts, and gifts
Civil fraud penalties
Challenges to whether the IRS followed its own procedures in asserting a penalty
Our Approach
Penalty defenses are built alongside the defense of the underlying tax, starting with the audit. Evidence of what the taxpayer knew, what professional advice was received, and what was disclosed on the return is gathered early, while it is still available. Fraud claims, especially those raised late in a case, get close review of both the evidence and the timing.
Experience
William A. Stone III has written for Tax Notes on how the IRS asserts penalties and how the Tax Court evaluates them, including civil fraud.
Contact Stone Tax Counsel
To discuss a matter, complete the form below or call (404) 494-0918. The firm works with clients nationwide.