Preparer Penalties and Civil Injunctions
The firm represents tax professionals who are the subject of proposed civil penalties and injunctions based on prior actions taken in connection with their preparation of tax returns. Preparer penalties can be imposed against CPAs, attorneys, enrolled agents and unlicensed tax return preparers. The penalties can be based on conduct relating to the preparation of a single return or on conduct relating to the preparation of a group of returns. While return preparer penalties are often quite small, the successful imposition of preparer penalties can result in a referral to the Treasury Department’s Office of Professional Responsibility. Thus, defending against preparer penalties is very important. Injunctions against preparers of tax returns are sought against return preparers who consistently engage in conduct which the IRS believes is improper. Requests for injunctions which would prevent a person form engaging in their livelihood must be taken very seriously. Our firm advises and assists tax professionals seeking to avoid or minimize possible return preparer penalties, both administratively and in court, and can represent return preparers against whom the IRS is seeking injunctive relief.