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White Paper

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IRS Tax Audits: Taxpayer Good Faith Misinterpretation of the Law

 

There is a long line of cases in the United States that side with the taxpayer for a good faith misunderstanding of the law.

It has been held that “Willfulness” is a voluntary, intentional violation of a known legal duty. A good faith misunderstanding of the law, whether or not objectively reasonable, negates willfulness. The complexities of the Internal Revenue Code and the massive case law interpreting the Code (along with the US Treasury Regulations, Revenue Rulings et al) result in the understanding that the complexities involved in the interpretation of the relevant tax laws may subject the taxpayer to a misinterpretation of the tax law.
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IRS Tax Audits: Taxpayer Good Faith Misinterpretation of the Law

Agenda

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IRS Tax Audits: Taxpayer Good Faith Misinterpretation of the Law

Faculty

Gary S. Wolfe

The Wolfe Law Group

Our author, Gary S. Wolfe, has more than 34 years of experience, specializing in IRS Tax Audits and International Tax Planning/Tax Compliance, and International Asset Protection.

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IRS Tax Audits: Taxpayer Good Faith Misinterpretation of the Law

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