<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>PENALTY U.S. 271.1(c) confirmed for reason that assesse is not an individual but company which is an AOP consisting of other corporate giants – the case should have been prepared and represented with full ground work. The view also need reconsideration.</title>
    <link>https://www.taxtmi.com/article/detailed?id=8715</link>
    <description>Confirmation of penalty relied on the assessee being an AOP of large companies and on an assessment that the assessee was consciously aware and knowingly furnished inaccurate particulars. The author argues a company/AOP acts through human agents and a Return Preparer Team (RPT); errors may arise from interpretation or computation despite use of professionals and auditors. Therefore, attributing subjective knowledge or deliberate concealment to a corporate assessee because of its size or AOP status is an insufficient basis for sustaining the penalty without fuller factual and evidentiary enquiry.</description>
    <language>en-us</language>
    <pubDate>Tue, 10 Sep 2019 06:00:01 +0530</pubDate>
    <lastBuildDate>Tue, 10 Sep 2019 06:00:01 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=586627" rel="self" type="application/rss+xml"/>
    <item>
      <title>PENALTY U.S. 271.1(c) confirmed for reason that assesse is not an individual but company which is an AOP consisting of other corporate giants – the case should have been prepared and represented with full ground work. The view also need reconsideration.</title>
      <link>https://www.taxtmi.com/article/detailed?id=8715</link>
      <description>Confirmation of penalty relied on the assessee being an AOP of large companies and on an assessment that the assessee was consciously aware and knowingly furnished inaccurate particulars. The author argues a company/AOP acts through human agents and a Return Preparer Team (RPT); errors may arise from interpretation or computation despite use of professionals and auditors. Therefore, attributing subjective knowledge or deliberate concealment to a corporate assessee because of its size or AOP status is an insufficient basis for sustaining the penalty without fuller factual and evidentiary enquiry.</description>
      <category>Articles</category>
      <law>Income Tax</law>
      <pubDate>Tue, 10 Sep 2019 06:00:01 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/article/detailed?id=8715</guid>
    </item>
  </channel>
</rss>