The Unavoidable Overlap of Promoter Investigations and Taxpayer Audits – Interactions and Insights



Enforcement actions by the IRS against alleged promoters of abusive transactions and the taxpayers who participate in them are firmly linked. Therefore, defending effectively against IRS challenges requires an understanding of the overlapping rules, standards, and procedures. This article explains unique aspects of so-called promoter penalties, various actions the IRS takes in connection with promoters, effects of such IRS measures on taxpayers who engaged in the transactions under scrutiny, recent events suggesting that promoter investigations might surge, and thoughts about the best path forward in the current environment.

Read the full article here.

About Hale E. Sheppard
HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a partner at Eversheds Sutherland.  He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues.

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