Leo Unzeitig
TXCPA
In an article published by TXCPA, Chamberlain Hrdlicka Shareholder Leo Unzeitig examines a TIGTA report revealing that the IRS improperly backdated managerial approvals for penalties totaling $68 million in seven syndicated conservation easement cases. Unzeitig discusses the statutory requirement for timely supervisory approval under IRC Section 6751(b), the IRS’s response to the findings, and concerns about the relatively modest disciplinary action taken against employees involved. The article also considers whether similar issues may exist beyond the cases reviewed by TIGTA and what the findings mean for the integrity of IRS penalty procedures.