Mark Allison Comments on IRS Finalizing Material Advisor Regulations
Mark D. Allison was quoted in CCH Standard Federal Tax Reports regarding the final regulations on material advisor penalties issued by the IRS. For the complete article, please click on the link above to view a PDF.
Excerpt taken from the article.
The final regulations provide important clarifications as to the scope and extent of the potential material advisor penalties and the factors considered by the IRS in rescinding those penalties," Mark Allison, member, Caplin & Drysdale, Chartered, New York, told CCH. "The regulations should serve as a reminder of the significant financial risks to material advisors who fail to comply with section 6707 disclosure requirements."