Defining the Reasonable Cause Defense to Tax and Information Reporting Penalties

"Reasonable cause" is a defense to most penalties in the Internal Revenue Code. This program, presented by tax attorney Megan Brackney, will discuss how "reasonable cause" is defined in various contexts, including delinquency penalties, accuracy penalties, foreign information return penalties, and penalties for noncompliance, such as failure to file Forms 8300 and to issue tax reporting forms, such as Forms W-2 and 1099.

Learning Objectives: 

1. Review the concepts of "reasonable cause" as a defense to tax penalties

2. Discuss Code sections, Treasury Regulations, and case law defining "reasonable cause" in different contexts

3. Identify techniques for presenting "reasonable cause" defenses to penalties