Article: The carrot and the stick: IRS's new disclosure initiative and guidelines for imposing the section 6662 accuracy-related penalty.

The federal tax system in the United States is a system of voluntary compliance and, as such, the Internal Revenue Service relies to a large extent on taxpayers' willingness to self-report their tax liabilities in order to administer the tax system. Congress has recognized that some taxpayers need additional encouragement to accurately report their tax liabilities and has enacted penalty provisions to deter noncompliance. (1) In some situations, the IRS has waived certain penalties in an effort to give taxpayers an opportunity (and incentive) to comply with new requirements of the Internal Revenue Code or Treasury Regulations. (2)

In late December 2001, the IRS ...

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