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ILM 200610018 (02/03/06)
The IRS can impose IRC 6700 penalty on a party to a bond transaction that made or furnished or caused to be made or furnished, a false or fraudulent statment regarding the tax benefit of the transaction.
Is the Internal Revenue Service precluded from asserting a penalty under I.R.C. §6700 against an attorney (bond counsel) who rendered false or fraudulent advice with respect to government mortgage revenue bonds if the Service decided not to pursue an audit to determine whether the bonds satisfied the requirements of section 103(a)?