Be Patient on Reportable Transaction Penalties, Attorneys Say

Mary Wood was quoted in the Tax Analysts article published on Feb, 2, 2022, Doc. 2022-3533, “Be Patient on Reportable Transaction Penalties, Attorneys Say,” by Kristen A. Parillo. Ms. Wood was a panelist at the recent American Bar Association Section of Taxation virtual meeting discussing the legal uncertainty regarding IRS penalty assessments amid pending court cases in which taxpayers have challenged the validity of IRS notices, issued without a formal comment period, that designate listed or reportable transactions requiring disclosure by taxpayers and material advisers.