Internal Revenue Service

Accuracy - Related Penalties for Taxpayers Involved in Tax Shelter Transactions: IRS Audit Techniques Guide Internal Revenue Service

This audit technique guide ("ATG") was developed to support the field in the consistent development and application of penalties when a taxpayer was involved in an abusive tax shelter, including "technical" tax shelters. This ATG is a Service-wide document, discussing penalty policy and considerations applicable to all taxpayers involved in tax shelter transactions. This guide is not intended to be all inclusive. In most cases, the examiner should refer to additional sources of information, including listing notices and disclosure initiatives, even if there is a thorough discussion of the issue in this guide. Although this ATG includes information from existing position papers, audit technique guides, and CPE materials that deal with specific listed transactions and identified transactions that have not been listed, it is not intended to replace these materials. The examiner should consult the penalty handbook, related audit technique guides, appeals settlement guidelines...