Section 6676 Erroneous Claim For Refund or Credit Penalty:  The Penalty Has No Reasonable Basis

The Tax Development Journal, Vol 1 (2009)

Section 6676 Erroneous Claim For Refund or Credit Penalty: The Penalty Has No Reasonable Basis

Sharyn M. Fisk, Esq., Heather Kim Lee, Esq.

Abstract

The new §6676 penalizes taxpayers for denial of certain income tax refund claims filed after May 25, 2007. Section 6676 imposes a new civil penalty equal to 20% of the “excessive amount,” unless the refund claim for the excessive amount has a reasonable basis.

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