Understatement penalties – Effect of and evaluating advice obtained

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Additional assessments are often accompanied by the imposition of understatement penalties (USP). The mere fact that a position taken by a taxpayer was based on advice obtained by the taxpayer may not, in itself, be sufficient grounds to reduce the USP imposed. This article considers a recent case and the consideration given by the court to a tax opinion obtained by the taxpayer.

 

For the full article: Part 1 and Part 2