In a previous post I discussed applying for a Collections Due Process Hearing (CDPH). And emphasized that the IRS has the burden of proof concerning penalties. All you really need to do in that case is deny that you filed a frivolous document. The Service must prove you did. To do so they must prove all the facts necessary to confirm that you are subject to the penalty, and that you submitted a document that meets the objective criteria set out in
Questions for a Frivolous Penalty CDP Hearing
Questions for a Frivolous Penalty CDP Hearing
Questions for a Frivolous Penalty CDP Hearing
In a previous post I discussed applying for a Collections Due Process Hearing (CDPH). And emphasized that the IRS has the burden of proof concerning penalties. All you really need to do in that case is deny that you filed a frivolous document. The Service must prove you did. To do so they must prove all the facts necessary to confirm that you are subject to the penalty, and that you submitted a document that meets the objective criteria set out in