Minor breach protections prevent penalties for trivial, rectifiable tax errors and require opportunity to be heard. Section 126 precludes penalties for minor breaches - including small-amount tax discrepancies and documentation errors apparent on the record and easily ... Summary
Minor breach protections prevent penalties for trivial, rectifiable tax errors and require opportunity to be heard.
Section 126 precludes penalties for minor breaches - including small-amount tax discrepancies and documentation errors apparent on the record and easily rectifiable - absent fraud or gross negligence; requires penalties to be commensurate with the breach; mandates an opportunity to be heard and specification in the penalty order of the nature of the breach and applicable provision; treats voluntary pre-discovery disclosures as a mitigating factor; and excludes cases where penalties are fixed sums or fixed percentages.
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