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6698 (a) (1) late filing penalty - flow through?

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    6698 (a) (1) late filing penalty - flow through?

    Does the late filing penalty flow through to the partners or responsible parties like trust fund penalties do, or is it attached to the partnership entity alone?

    In other words, if the partnership holds no significant assets, and its business can be performed within a newly formed partnership or other entity, can one simply cease activities under that partnership, distribute whatever assets there are to the partners, file a final return and walk away from the penalty?
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