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Well, maybe “trickle” is more accurate. As of March 13, 75 taxpayers have taken already taken advantage of the IRS so-called tax shelter amnesty program, as set forth in Announcement 2002-2, according to a report by Tax Analysts. The deadline is April 22; as with any such deadline, we can expect filings to come in mostly in the last few days.
The program waives penalties for a number of return positions (not just those involving tax shelters) if they are fully disclosed. The program is attractive to taxpayers who might have an, ahem, aggressive position on their tax return that would not avoid a penalty on examination even if it were fully disclosed. For taxpayers with a high likelihood of audit, the program lowers the stakes when IRS comes looking at the return.
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Joe Kristan writes the Tax Update items, and any opinions expressed or implied are not necessarily shared by anyone else at Roth & Company, P.C. Address questions or comments on Tax Updates to