What You Don't Know Can Hurt You: Paying for Preparer Fraud

Posted: 14 Jul 2016

See all articles by Adam Wallwork

Adam Wallwork

Osler Hoskin & Harcourt LLP (New York)

Date Written: December 21, 2015

Abstract

In this article, Wallwork examines the circuit split that has recently developed over whether a return preparer's fraud is sufficient to toll the three-year statute of limitations on federal tax assessments. By rejecting the Tax Court's rule, the Court of Federal Claims and the Federal Circuit have created a situation in which wealthy, well-advised taxpayers may be able to completely escape the perpetual liability and compound interest that their less-fortunate counterparts must face.

Keywords: Tax, Fraud, Preparer Fraud, Accounting, Tax Court, Claims Court, Federal Circuit, Court of Claims, Statute of Limitations, Section 6501(c)(1)

JEL Classification: F38, H2

Suggested Citation

Wallwork, Adam, What You Don't Know Can Hurt You: Paying for Preparer Fraud (December 21, 2015). Tax Notes, Vol. 149, No. 12, 2015, Available at SSRN: https://ssrn.com/abstract=2809274

Adam Wallwork (Contact Author)

Osler Hoskin & Harcourt LLP (New York) ( email )

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