U.S. IRS Practice Unit on Tax Shelter Promoter Investigations

The US Internal Revenue Service (IRS) has released a practice unit on Tax Shelter Promoter Investigations Under IRC 6700. The process overview of the practice unit includes the following:

IRC 6700 permits assertion of penalties against any person who:

• Organizes or assists in the organization of a partnership or other entity, an investment plan or arrangement, or any other plan or arrangement; or
• Participates (directly or indirectly) in the sale of any interest in an entity or plan or arr…