Sec. 6694 tax return reporting standards for preparers * Sec. 7216 regulations.

The Tax AdviserVol. 39 Nbr. 5, May 2008

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Sec. 6694 tax return reporting standards for preparers * Sec. 7216 regulations.

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The Sec. 6694 tax return reporting standards applicable to tax return preparers were increased as part of the Iraq war funding legislation enacted on May 25, 2007 (P.L. 110-28). The standard increased from "realistic possibility of success" to "more likely than not" (MLTN) for undisclosed nontax-shelter items.

Although the increase in the standards was a major change in tax policy, it was not the subject of a hearing and was not based on a recommendation from Treasury. The change came as a surprise even to the IRS (the IRS Chief Couns...

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