Tax Law Blog | IRS Tax Attorneys

An assessment is a determination by a government agency that you owe tax.

In general, an assessment must be made within 3 years from the date the return was filed.

In the case of a false return, a willful attempt to evade tax, failure to file a return, or pursuant to agreement between you and the government agency, the assessment can be made at any time.
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Tax penalties can be avoided if the relevant facts affecting the item’s tax treatment are adequately disclosed in the tax return. However, disclosure cannot be used to avoid incorrect valuation tax penalties.

Another way to dispute a tax penalty is to show that substantial authority exists for your tax treatment of an item. To establish substantial authority for a position, look to tax documents published in the Internal Revenue Bulletin, tax court cases, private letter rulings issued by the IRS, and some congressional reports. Authority supporting your tax position should be substantial in relation to the weight of authorities supporting contrary tax treatment.

If a tax penalty is assessed by the IRS, you can appeal. While the appeal is under consideration, payment of the tax penalty is suspended. You also have a right to representation and can ask to have a meeting with the IRS.

The tax penalty for filing a frivolous tax return is not based on your tax liability and will be assessed immediately and added to any other tax penalties
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For IRS Tax representation The Sheppard Law Offices. Arrange for a free consultation by calling 877-505-9455.