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IRS Rules There is No Statute of Limitations on Appraiser Penalty

In Chief Counsel generic legal advice (EMISC 2007-0017), the IRS has concluded that it may assess a Code Sec. 6695A penalty against an appraiser for appraisals prepared after May 25, 2007 that are used in connection with an estate or gift tax return or claim for refund or credit that results in a gross valuation misstatement. In addition, the IRS concluded that there is no period of limitations that applies to the assessment of a Code Sec. 6695A penalty.
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