On May 16, 2012 the IRS revised the sections of the Internal Revenue Manual dealing with the 6707A penalty. The Manual provides little in the way of new guidance, but it does reference updated interim guidance that may be helpful to those dealing with technical issues.
The attorneys of Williams Coulson regularly represent clients with section 6707A matters before the Internal Revenue Service. Please do not hesitate to contact Michael E. Lloyd, F. Jefferson Bragdon, or Stephen J. Pieklik should you have any questions concerning the 6707A penalty.
IRS CIRCULAR 230 TAX ADVICE DISCLAIMER: Any federal tax advice contained in this communication (including attachments or enclosures) is not intended or written to be used, and it cannot be used, for the purpose of (1) avoiding any penalty that may be imposed by the Internal Revenue Service or (2) promoting, marketing or recommending any transaction or matter.