This ATG is a Service-wide document, discussing penalty policy and considerations applicable to all taxpayers involved in tax shelter transactions.Īlaskan Commercial Fishing: Catcher Vessels Part One (PDF, 279K) This audit technique guide (�ATG�) was developed to support the field in the consistent development and application of penalties when a taxpayer was involved in an abusive tax shelter, including �technical� tax shelters. Link at the bottom of the page to obtain a FREE copy from Adobe.Īccuracy - Related Penalties For Taxpayers Involved In Tax Shelter Transactions (PDF, 789K) You do not have the appropriate Acrobat Reader plugged into your browser, click on the There are different Acrobat Readers for different platforms.
#IRS PASSIVE ACTIVITY AUDIT GUIDE PDF#
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Practices, industry terminology and other information to assist examiners in performing Guides contain examination techniques, common and unique industry issues, business Of the approach used is the development and publication of Audit Techniques Guides. Segment may be an industry such as construction or entertainment, a profession likeĪttorneys or real estate agents or an issue like passive activity losses. The Market Segment Specialization Program (MSSP)įocuses on developing highly trained examiners for a particular market segment. For Tax Professionals > Market Segment Specialization Programs
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