Under pressure from Congress, the Internal Revenue Service has once again extended its moratorium on collection enforcement actions on certain types of tax shelter penalties.
Last month, the Senate unanimously approved a bill that would prevent small businesses from incurring tax penalties aimed at large corporations and wealthy individuals who invest in tax shelters (see Senate Passes Bill to Fix Small Biz Tax Penalties). The Small Business Penalty Fairness Act revises Section 6707A of the Tax Code to set the penalty for failure to disclose reportable transactions to the IRS at 75 percent of the tax benefit received.
Last year, the IRS temporarily suspended its efforts to collect penalties on some listed tax transactions until Sept. 30, and later until the end of the year, after hearing complaints from members of Congress and National Taxpayer Advocate Nina Olson about the disproportionate penalties levied on small-business owners (see IRS Extends Moratorium on Small Business Tax Shelter Penalties).
On Wednesday, IRS Commissioner Doug Shulman notified Congress that the IRS is extending until June 1, 2010, the current moratorium on collection enforcement actions relating to tax shelter penalties assessed under Section 6707A. In addition, the IRS will continue to hold off on filing new notices of lien on amounts due solely related to Section 6707A penalties until June 1, 2010.
Chris Hellums
PITTMAN, DUTTON, & HELLUMS, P.C.
2001 Park Place North
1100 Park Place Tower
Birmingham, Alabama 35203
(205) 322-8880
(205) 328-2711 (facsimile)
Email: chrish@pdkhlaw.com
Firm Website: www.pdkhlaw.com
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Disclaimer
No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.
Disclaimer...
The material on this web site has been prepared by Chris Hellums. The material is for informational purposes only and does not constitute legal advice. The material does not necessarily reflect the opinions of Chris Hellums or any of its attorneys or clients, and is not guaranteed to be correct, complete, or up to date.
Transmission of the material on this site is not intended to create, and receipt does not constitute, an attorney-client relationship. This information is not intended to substitute for obtaining legal advice from an attorney. Each person's legal needs are unique, and these materials may not be applicable to your legal situation. No person should act or rely on any information in this site without seeking the advice of an attorney.
Chris Hellums has affiliations in particular cases with attorneys licensed to practice in different state court in the United States.
If you communicate with us through this site or otherwise in connection with a matter for which we do not already represent you, it is possible that your communication may not be treated as privileged or confidential. If you communicate with us by e-mail on a matter for which we already represent you, please remember that Internet e-mail is not secure and you should avoid sending sensitive or confidential Internet e-mail messages unless they are adequately encrypted. Nevertheless, we will respond by e-mail to your e-mail inquiry, unless you ask us to respond in some other way.
To the extent the State Bar rules require us to designate a principal office and/or single attorney responsible for this site, Pittman, Dutton, Kirby and Hellums P.C. designates Chris Hellums as the attorney responsible for this site. He is located at 2001 Park Place North, Birmingham, Alabama 35203.
Please be aware that the transmission of an e-mail inquiry itself does not create an attorney-client relationship. Chris Hellums cannot serve as your counsel in any matter unless you and our firm expressly agree in writing that we serve as your attorney. You should also be aware that the Statute of Limitations (the deadline imposed by law within which you may bring a lawsuit) may severely limit the time remaining for you to file any potential claims you may have.
Chris Hellums does not offer any guarantee of case results. The cases mentioned in this site are illustrative of the array of matters our firm handles or is interested in handling. Each case must stand on its own facts and circumstances.
This web site may be considered advertising in some jurisdictions under the applicable law and ethical rules. The hiring of an attorney is an important decision that should not be based solely upon advertisements. Before you decide to retain us, ask us to send you free written information about our qualifications and experience. Our attorneys do not wish to enter into a representation with anyone desiring representation based on viewing these materials in a state where this web site fails to comply with the laws and professional responsibility rules of the state.
Required State Specific Disclaimers:
Alabama:
No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.
Disclaimer...
The material on this web site has been prepared by Chris Hellums. The material is for informational purposes only and does not constitute legal advice. The material does not necessarily reflect the opinions of Chris Hellums or any of its attorneys or clients, and is not guaranteed to be correct, complete, or up to date.
Transmission of the material on this site is not intended to create, and receipt does not constitute, an attorney-client relationship. This information is not intended to substitute for obtaining legal advice from an attorney. Each person's legal needs are unique, and these materials may not be applicable to your legal situation. No person should act or rely on any information in this site without seeking the advice of an attorney.
Chris Hellums has affiliations in particular cases with attorneys licensed to practice in different state court in the United States.
If you communicate with us through this site or otherwise in connection with a matter for which we do not already represent you, it is possible that your communication may not be treated as privileged or confidential. If you communicate with us by e-mail on a matter for which we already represent you, please remember that Internet e-mail is not secure and you should avoid sending sensitive or confidential Internet e-mail messages unless they are adequately encrypted. Nevertheless, we will respond by e-mail to your e-mail inquiry, unless you ask us to respond in some other way.
To the extent the State Bar rules require us to designate a principal office and/or single attorney responsible for this site, Pittman, Dutton, Kirby and Hellums P.C. designates Chris Hellums as the attorney responsible for this site. He is located at 2001 Park Place North, Birmingham, Alabama 35203.
Please be aware that the transmission of an e-mail inquiry itself does not create an attorney-client relationship. Chris Hellums cannot serve as your counsel in any matter unless you and our firm expressly agree in writing that we serve as your attorney. You should also be aware that the Statute of Limitations (the deadline imposed by law within which you may bring a lawsuit) may severely limit the time remaining for you to file any potential claims you may have.
Chris Hellums does not offer any guarantee of case results. The cases mentioned in this site are illustrative of the array of matters our firm handles or is interested in handling. Each case must stand on its own facts and circumstances.
This web site may be considered advertising in some jurisdictions under the applicable law and ethical rules. The hiring of an attorney is an important decision that should not be based solely upon advertisements. Before you decide to retain us, ask us to send you free written information about our qualifications and experience. Our attorneys do not wish to enter into a representation with anyone desiring representation based on viewing these materials in a state where this web site fails to comply with the laws and professional responsibility rules of the state.
Required State Specific Disclaimers:
Alabama:
No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.