Fillable Accuracy - Related Penalties For Taxpayers Involved In Tax Shelter Transactions Audit Technique Guide (ATG). This audit technique guide ("ATG") was developed to support the field in the consistent development and application of penalties
52 Exhibit 9 IRS Announcement 2002-2. 54 Exhibit 10 Commissioner Memorandum dated December 29 2003. 58 Table of Contents / Chapter 2 Coverage This audit technique guide ATG was developed to support the field in the consistent development and application of penalties when a taxpayer was involved in an abusive tax shelter including technical tax shelters. Internal Revenue Service Accuracy - Related Penalties For...
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