Kroner’s Impact on the IRS’ Penalty Approval Requirement Under Code Sec. 6751
Tax attorneys Jim Dawson, Alex Olama and Chad Vanderhoef co-authored an article in the Tax Magazine about issues that Internal Revenue Code Section 6751 has caused because of its ambiguity. The authors break down three potential resolutions for these issues. They clarify the issues that a get-out-of-jail-free card tax system causes when a system does not treat taxpayers on a consistent basis, saying those that conduct the same action should end up with the same treatment. The authors believe that transparency is key to ensure a fair and equitable tax system.