IRS Clarifies Position on Gross Valuation Penalty
Summary
In Email Chief Counsel Advice, the IRS has stated that so long as property qualifies for a charitable deduction, there is no reasonable cause/good faith exception with respect to the 40% gross valuation penalty.
ECC 201202026
Full Text:
UILC: 6664.03-00
Release Date: 1/13/2012
ID: CCA_2011122108424964
Office: * * *
Office: * * *
From: * * *
Sent: Wednesday, December 21, 2011 8:42:51 AM
To: * * *
Cc:
Subject: FW: 6662(h) penalty post-Aug 17, 2006
So long as it is charitable deduction property, I agree that there is no reasonable cause/good faith exception with respect to the 40% gross valuation penalty.
I wouldn't have a lot to say about the penalty, but I could talk about it just a little.
Add comment
Comments