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IRS MAKES 'SON OF BOSS' SETTLMENT OFFER
May 06, 2004
The IRS has made what it says will be its most generous offer to settle the "Son of BOSS" tax shelter cases (Announcement 2004-46). These cases used partnerships to create millions of dollars of tax losses. A version of this shelter became notorious when it was featured on "60 Minutes."
Under the offer, taxpayers will have to concede all tax benefits, except for limited benefits for out of pocket costs. Taxpayers who disclosed their involvement under the disclosure amnesty of Announcement 2002-2 will have no penalties; other taxpayers may qualify to limit their underpayment penalties to 10%. These normally can go as high as 25% (Correction: 40%)
Taxpayers have until June 21 to accept the offer.
The TaxProf Blog has more.
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