Added thoughts
In Danny's case, client supplied the figure, she had no reason to question it, so she did no wrong and has no liability to client to reimburse any penalty.
The regulations I referred to above are meant in extreme cases where client does nothing wrong yet relies on (what he thinks is) competent tax help. Any tax pro who was the preparer of such a return should use this regulation (1.6661-6) sparingly and judiciously,
for yes, it might open him up questioning. But I've used it twice and nary a word from IRS.
yes, those two were my mistakes.
JohnH, I smiled when I read your question, for I could see from where you were coming.
Thank goodness these are the exception.
for Travis: in Danny's case if client assents to a 1040x, the interest should be added as a footnote on
page one and a check sent for tax and interest.
IOW, present IRS with their due minus the penalty and they will regard the 1040x as a "fait accompli".
In Danny's case, client supplied the figure, she had no reason to question it, so she did no wrong and has no liability to client to reimburse any penalty.
The regulations I referred to above are meant in extreme cases where client does nothing wrong yet relies on (what he thinks is) competent tax help. Any tax pro who was the preparer of such a return should use this regulation (1.6661-6) sparingly and judiciously,
for yes, it might open him up questioning. But I've used it twice and nary a word from IRS.
yes, those two were my mistakes.
JohnH, I smiled when I read your question, for I could see from where you were coming.
Thank goodness these are the exception.
for Travis: in Danny's case if client assents to a 1040x, the interest should be added as a footnote on
page one and a check sent for tax and interest.
IOW, present IRS with their due minus the penalty and they will regard the 1040x as a "fait accompli".
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