The Top 10 Tax Preparer
(and Tax Advisor)
Penalties

(and how to avoid them!)

Most professionals who give tax advice or prepare tax returns know that great care must be taken regarding what appears (or doesn’t appear) or clients’ returns.

But few tax advisors or preparers know exactly where “the line” is - - and the nature and extent of penalties that may apply to them if that line is crossed.

For example, do you know:

  • Who is a preparer?
  • Who is not a preparer?
  • What is a “non-signing tax return preparer”?
  • What is the 5% rule for “non-signing tax return preparers”?
  • What’s the bigger concern: the preparer penalty or being reported to the Office of Professional Responsibility?
  • What does it mean to have a “reasonable basis” for a position on a return?
  • What does it mean to have “substantial authority” for a position on a return?
  • Does disclosing a position taken on a return – IRS Form 8275 – increase the risk of an audit?
  • Under what circumstances does a tax attorney’s opinion letter give the tax return preparer “reasonable cause”?
  • Under what circumstances does reliance on a CPA give the taxpayer “reasonable cause”?
  • What’s the relationship between the preparer penalty of Section 6694 and the taxpayer penalty of Section 6662?
  • What problem does the Section 7701(o) economic substance doctrine 40% penalty (Section 19774 of the California Revenue & Taxation Code) create for preparers?
  • Does the tax return preparer have exposure if the taxpayer is hit with a civil fraud penalty?
  • What responsibility does a tax return preparer have to monitor a taxpayer’s activities for “abusive tax shelters” under Section 6700?
  • How likely is it that a tax return preparer will be held liable for “aiding and abetting [the] understatement of tax liability” under Section 6701?
  • How easy is it to have a taxpayer engage in a “reportable transaction” under Section 6707A?

You need to know and that’s why we’ve asked nationally renowned tax attorney, Bruce Givner, Esq., to present a special, 90-minute presentation entitled, “The Top 10 Preparer (and Advisor) Tax Penalties”.

  • Program Title: The Top 10 Preparer (and Advisor) Tax Penalties
  • Speaker:
  • Duration: 90 Minutes

Bruce Givner

Esq.
Bruce Givner

Bruce Givner, Esq. is an estate and tax planning attorney of the Law Firm of Givner and Kaye, located in Los Angeles, California. Mr. Givner graduated from U.C.L.A., Columbia University Law School, and N.Y.U.’s Graduate Tax Law Program and specializes in the area of asset protection and advanced estate planning. He has personally worked with Mr. Philip Kavesh for over 30 years and continues to serve “of counsel” to Mr. Kavesh’s law firm, Kavesh, Minor and Otis, Inc.

Mr. Givner has been cited as a “tax expert” by the U.S. Tax Court, the California Court of Appeals, and the Wall Street Journal. He’s also written books on estate tax planning for the California CPA Society and the AICPA, and has co-authored three for the California Bar Association. He represented the winning taxpayers in the 1994 Tax Court case L&B Pipe and Supply, in which the IRS sought almost $2,000,000 in back taxes and interest due to alleged unreasonable compensation. The U.S. Tax Court awarded the IRS nothing.

His most recent Tax Court case, involving an FLP established on August 3, 2002, where the parent died on August 8, 2002, settled one month before trial when the IRS conceded that IRC §2036 did not apply.

IMPORTANT NOTICE REGARDING CE CREDIT

The Ultimate Estate Planner, Inc. and the presenter are not registered Continuing Education Sponsors and this program is not pre-approved for continuing education credit for any state or regulatory agency.

However, please note that each program includes a Certificate of Completion and, depending on the license and the regulatory agency for which governs a participant’s CE credit, some professionals may be able to self-report his or her participation and receive credit. It is the responsibility of the participant to complete any process necessary to seek self-reported CE credit for his or her participation. By registering for a teleconference (or purchasing on On-Demand program), you understand that CE credit is not guaranteed or warranted by the presenter or The Ultimate Estate Planner, Inc.

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