Reply to IRS penalty- Settle or proceed to litigation?

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[quote=Anonymous]OP: I remain concerned that your attorney told you that you had to pay the assessment before challenging in court (not true for Tax Court, but true for Court of Claims or for Federal District Court) and remain concerned that no one told you how the assessment was calculated.

You wrote that both your tax attorney & your CPA made mistakes in handling this matter.

Appears that the penalty is 5% of the amount of the gift per month up to a maximum penalty of 25% of the amount of the gift. So if the gift amount was $160,000, then you would be penalized $40,000 if you filed late by 5 or more months. Is this your understanding OP ?

None reporting of gifts from foreigners raise money laundering concerns.

OP: In part, due to your silence, I suspect that the reduced penalty of $20,000 is a good deal. Unlikely that you will receive much sympathy for lack of funds/inability to pay since you received a gift of over $100,000 from a foreigner.

This seems to be a very simple tax matter.[/quote]

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