Promoter Penalties

Once upon a time, the consequences of poor tax reporting were borne almost exclusively by the taxpayer. The tax laws, however, in the last ten years have greatly increased the penalties and consequences for tax professionals who engage in overly aggressive income tax positions and tax shelters. Of course, a ‘tax shelter’ may be in the eye of the beholder – or it may be defined with some exactness in the IRS publications on ‘listed transactions’.