New Preparer Rules: More Or Less Penalty?
本文回顾了1976年通过的《国内收入法典》第6694条及1980-1981年相关裁决，分析了对税务申报表编制人因疏忽或故意违规导致少报税款而施加处罚的扩展边界，并指出与《税务实务责任声明》的冲突之处。
Abstract In 1976 Congress adopted Section 6694, which provides penalties for preparers who understate a liability due to negligent or intentional disregard of rules and regulations. Rulings issued in 1980 and 1981 expand the boundaries of these penalties by focusing on the nature, frequency and materiality of errors on the tax return. Accountants should be aware of the requirements imposed by IRS in the area of research of tax issues, office procedure and documentation, and disclosure of differences. This article reviews the statutory law and rulings, highlighting areas of uncertainty, and conflict with the Statements on Responsibilities in Tax Practice.