Penalty Provisions. The law provides for a penalty to be imposed where taxpayers make a substantial understatement of their tax liability. For individual taxpayers, asubstantial understatement exists when the understatement for the year exceeds the greater of 10 percent of the tax required to be shown on the return, or $5,000. The penalty is 20 percent of the tax underpayment. Taxpayers may seek to avoid all or partof the penalty by showing (1) that they acted in good faith and there was reasonable cause for the understatement, (2) that the understatement was based on substantial authority, or (3) that the relevant facts affecting the item’s tax treatment were adequately disclosed on the return. You agree to advise us if you wish disclosure to be made in yourreturns or if you desire us to identify or perform further research with respect to any material tax issues for the purposes of ascertaining whether, in our opinion, there is “substantial authority” for the position proposed to be taken on such issues in your returns.
Appears in 1 contract
Samples: Tax Services Agreement
Penalty Provisions. The law provides for a penalty to be imposed where taxpayers make a substantial understatement of their tax liability. For individual corporate taxpayers, asubstantial a substantial understatement exists when the understatement for the year exceeds the greater of 10 percent of the tax required to be shown on the return, or $5,00010,000. The penalty is 20 percent of the tax underpayment. Taxpayers may seek to avoid all or partof part of the penalty by showing (1) that they acted in good faith and there was reasonable cause for the understatement, (2) that the understatement was based on substantial authority, or (3) that the relevant facts affecting the item’s 's tax treatment were adequately disclosed on the return. You agree to advise us if you wish disclosure to be made in yourreturns your returns or if you desire us to identify or perform further research with respect to any material tax issues for the purposes of ascertaining whether, in our opinion, there is “substantial authority” for the position proposed to be taken on such issues in your Services Description returns.
Appears in 1 contract
Samples: Tax Services Agreement
Penalty Provisions. The law provides for a penalty to be imposed where taxpayers make a substantial understatement of their tax liability. For individual taxpayers, asubstantial a substantial understatement exists when the understatement for the year exceeds the greater of 10 percent of the tax required to be shown on the return, or $5,000. The penalty is 20 percent of the tax underpayment. Taxpayers may seek to avoid all or partof part of the penalty by showing (1) that they acted in good faith and there was reasonable cause for the understatement, (2) that the understatement was based on substantial authority, or (3) that the relevant facts affecting the item’s tax treatment were adequately disclosed on the return. You agree to advise us if you wish disclosure to be made in yourreturns your returns or if you desire us to identify or perform further research with respect to any material tax issues for the purposes of ascertaining whether, in our opinion, there is “substantial authority” for the position proposed to be taken on such issues in your returns.
Appears in 1 contract
Samples: Tax Services Agreement
Penalty Provisions. The law provides for a penalty to be imposed where taxpayers make a substantial understatement of their tax liability. For individual corporate taxpayers, asubstantial a substantial understatement exists when the understatement for the year exceeds the greater of 10 percent of the tax required to be shown on the return, or $5,00010,000. The penalty is 20 percent of the tax underpayment. Taxpayers may seek to avoid all or partof part of the penalty by showing (1) that they acted in good faith and there was reasonable cause for the understatement, (2) that the understatement was based on substantial authority, or (3) that the relevant facts affecting the item’s 's tax treatment were adequately disclosed on the return. You agree to advise us if you wish disclosure to be made in yourreturns your returns or if you desire us to identify or perform further research with respect to any material tax issues for the purposes of ascertaining whether, in our opinion, there is “substantial authority” for the position proposed to be taken on such issues in your returns.
Appears in 1 contract
Samples: Tax Services Agreement
Penalty Provisions. The law provides for a penalty to be imposed where taxpayers make a substantial understatement of their tax liability. For individual corporate taxpayers, asubstantial understatement exists when the understatement for the year exceeds the greater of 10 percent of the tax required to be shown on the return, or $5,00010,000. The penalty is 20 percent of the tax underpayment. Taxpayers may seek to avoid all or partof the penalty by showing (1) that they acted in good faith and there was reasonable cause for the understatement, (2) that the understatement was based on substantial authority, or (3) that the relevant facts affecting the item’s 's tax treatment were adequately disclosed on the return. You agree to advise us if you wish disclosure to be made in yourreturns or if you desire us to identify or perform further research with respect to any material tax issues for the purposes of ascertaining whether, in our opinion, there is “substantial authority” for the position proposed to be taken on such issues in your returns.
Appears in 1 contract
Samples: Tax Services Agreement
Penalty Provisions. The law provides for a penalty to be imposed where taxpayers make a substantial understatement of their tax liability. For individual corporate taxpayers, asubstantial understatement exists when the understatement for the year exceeds the greater of 10 percent of the tax required to be shown on the return, or $5,00010,000. The penalty is 20 percent of the tax underpayment. Taxpayers may seek to avoid all or partof the penalty by showing (1) that they acted in good faith and there was reasonable cause for the understatement, (2) that the understatement was based on substantial authority, or (3) that the relevant facts affecting the item’s 's tax treatment were adequately disclosed on the return. You agree to advise us if you wish disclosure to be made in yourreturns or if you desire us to identify or perform further research with respect to any material tax issues for the purposes of ascertaining whether, in our opinion, there is “substantial authority” for the position proposed to be taken on such issues in your Services Description returns.
Appears in 1 contract
Samples: Tax Services Agreement