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Правни съображения за бизнес финанси и счетоводно съответствие

Section 6694 Tax Preparer Penalties: How Unreasonable Positions, Willful Conduct, and Section 6695 Due Diligence Failures Cost CPAs and EAs Real Money

Section 6694 imposes preparer penalties of $1,000 or 50% of fees for unreasonable positions, escalating to $5,000 or 75% for willful or reckless conduct. Section 6695(g) adds roughly $650 per EITC, CTC, AOTC, or head-of-household failure on every return. Here is how CPAs and EAs document, disclose, and defend their way out of them.

IRS Statute of Limitations Under Section 6501: How Long the IRS Has to Audit, Assess, or Refund

Section 6501 gives the IRS three years from filing to assess tax — but the window stretches to six years for omissions over 25% of gross income or basis overstatements, and never closes at all for unfiled returns, fraud, or undisclosed foreign reporting. A practical guide to ASED, refund claim windows under Section 6511, the 10-year CSED, Form 872 consents, and what records to keep.