According to Law360, a Swiss couple owe accuracy penalties totaling $500,000 for 2006 and 2007 because their amended returns were submitted after a summons, the U.S. Tax Court said on August 31, 2022 in the case of Johannes et ux. v. Commissioner, docket number 14410-15, in the U.S. Tax Court.
Johannes and Linda Lamprecht Filed Their Amended Returns For 2006 And 2007 After The Internal Revenue Service Submitted A John Doe Summons To UBS That Applied To Them, The Tax Court Said.
Thus, their amended returns weren't "qualified amended returns" under Treasury Regulation Section 1.6664-2(c)(3)(i)(D) and the couple were liable for the penalties for understating income.
The Tax Court also found that the IRS had complied with a supervisory approval requirement and that assessing the penalties wasn't barred by a statute of limitations.
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