Mary Wood was quoted in a Tax Analysts article on February 2, 2022

Mary Wood, firm partner was quoted in the Feb. 2, 2022, Tax Analysts article, “Be Patient on Reportable Transaction Penalties, Attorneys Say.”

Mary E. Wood of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P. said she’s telling her clients that even with the encouraging signs from the CIC Services case, she doesn’t expect IRS Exam or IRS Appeals to budge anytime soon in their position on reportable transaction penalties. “I don’t think there’s anything wrong with us raising the same arguments in Exam or Appeals that are being asserted in Mann Construction or CIC, depending on the notice and whether it’s a taxpayer or adviser.” Wood said.

“But I think we can preserve our arguments there and get them on the record, understanding that we don’t think the IRS will be receptive to those arguments,” Wood continued. “And then making a strategic decision on how to move forward so we allow the legal landscape to settle, hopefully in favor of taxpayers and material advisers, and perhaps getting notices set aside.”

Paying the penalty and then filing a refund claim is a good option for taxpayers who can afford it, said Wood. “But then you have some clients that simply won’t be in that position, and there I think we just have to push it out as long as you can and see how things do shake out,” she added.