No Reasonable Cause Exemption for Failure to File

In ILM 201733013 the Service stated that Rev. Proc. 84-35,1984-1 CB 509, does not provides an automatic reasonable cause exemption from penalties for failing the requirement of filing a Form 1065, U.S. Return of Partnership Income to partnerships with ten or fewer partners .According to the Service,...

Full description

Saved in:
Bibliographic Details
Published in:Journal of Taxation 2017-11, Vol.127 (5), p.234-234
Main Authors: st, David L, Geils, Edwin, Grais, Susan M, Hodges, Charles E
Format: Article
Language:English
Subjects:
Compliance
Deadlines
Fines & penalties
Income tax returns
Income taxes
Partnerships
TEFRA 1982-US
Waivers
Online Access:Get full text
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Summary:In ILM 201733013 the Service stated that Rev. Proc. 84-35,1984-1 CB 509, does not provides an automatic reasonable cause exemption from penalties for failing the requirement of filing a Form 1065, U.S. Return of Partnership Income to partnerships with ten or fewer partners .According to the Service, generally, when a partnership fails to file a partnership return, the partnership is automatically subject to the Section 6698 penalty. The individual partners' income tax returns, even if timely filed and complete, are not linked together during their initial processing. [...]the Service generally does not know how many partners are in the partnership or whether all of the partners timely filed their income tax returns unless and until the partnership (or one of its partners) is selected for an audit. [...]partnerships having a trust or corporation as a partner, tier partnerships, and partnerships where each partner's interest in the capital and profits are not owned in the same proportion, or where all items or income, deductions, and credits are not allocated in proportion to the pro rata interest, are not covered by Rev. Proc. 84-35.
ISSN:0022-4863