The accompanying article provides a comprehensive analysis of the civil tax penalty structure of the Internal Revenue Code. Civil tax penalties are an important tool for encouraging taxpayer compliance with tax laws. Tax penalties must be administered properly and penalties must be effective in order to encouraging compliance. However, despite this clear notion of encouraging compliance, many have argued the need for civil tax penalty reform. With the increasing growth of the number of civil tax penalties, significant changes are needed to promote voluntary compliance. The 2009 AICPA report addressed 12 specific issues with the civil tax penalty structure. This article begins with a comprehensive historical analysis of the civil tax penalty structure. The article then briefly discusses the common civil tax penalties under the current structure and then focuses on the 12 specific issues presented in the AICPA report, providing a more in depth analysis and discussion on these issues.
Available at: http://works.bepress.com/nicole_johnson/1/