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Taxpayer timely filed 2020 return on April 15, 2021. Taxpayer reported $80,000 of taxable income and a tax liability of $16,000 that was paid in
Taxpayer timely filed 2020 return on April 15, 2021. Taxpayer reported $80,000 of taxable income and a tax liability of $16,000 that was paid in full at the time of filing. IRS notified Taxpayer of Audit on November 1, 2021. Following the Audit (which lasted 3 months), IRS made 4 adjustments to the Taxpayer’s taxable income of $15,000 (Adjustment A), $25,000 (Adjustment B), $15,000 (Adjustment C) and $15,000 (Adjustment D). The IRS asserted that Adjustment A was subject to no penalty, Adjustment B was subject to a 20% substantial understatement penalty under IRC 6662(b)(2), Adjustment C was subject to a 40% substantial valuation misstatements due to an overstated basis under IRC 6662(h) and Adjustment D was subject to a 75% fraud penalty under IRC 6663(a). For simplicity purposes, assume the relevant tax brackets for the 2020 tax period for an individual filer were as follows: Over $80,000 – Up to $100,000 20% Over $100,000 – Up to $120,000 20,000 + 25% (of the amount over $100K) Over $120,000 – Up to $140,000 25,000 + 30% (of the amount over $120K) Over $140,000 – Up to $160,000 31,000 + 35% (of the amount over $140K) The IRS asserts a Tax Deficiency of $18,500.
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