Tax Shelter & Promoter Defense

  • “Section 6700” Investigations – A Section 6700 penalty is intended to stop promotion of abusive tax shelters. Over the years IRS has expanded its application of Section 6700 penalties to cases for which Congress, arguably never intended the penalty to be applied. Unfortunately, taxpayers that have taken every step to comply with tax laws may find themselves under scrutiny for possible assessment of a Section 6700 penalty.


  • Return Preparer Investigations – Tax preparers are subject to numerous laws and regulations covering issues ranging from privacy to ethics. The IRS can initiate investigations for many reasons and are conducted by different arms of the IRS including the Office of Professional Responsibility, Revenue Agents, or the Criminal Investigation Division.