Christopher S. Rizek to Speak at The University of Texas at Austin School of Law's 60th Annual Taxation Conference
Program: Penalties, More and More: How to Assess and Deal with Exposures and Seek Relief
Event Sponsor: The University of Texas at Austin School of Law, 60th Annual Taxation Conference
Penalties, including stricter liability penalties, have become ever more frequent and sizable. Advising clients with respect to their exposures, and how and when professional advice and other factors may be used in avoiding or, if necessary, defending them, is critical. Further, assessing the professional's own exposures and dealing with them in examinations and appeals has become a necessary practice skill. Every tax advisor at some point will be faced with a missed regulatory election, whether the client's or the advisor's own doing. This panel addresses practice issues related to penalties and issues relating to curing a late or missed regulatory election, with a focus on 9100 relief (both automatic and non-automatic) and the practical aspects of maximizing the success of a 9100 relief request.