Accuracy - Related Penalties For Taxpayers Involved In Tax Shelter Transactions Audit Technique Guide

Internal Revenue Service Accuracy - Related Penalties For Taxpayers Involved In Tax Shelter Transactions Audit Technique Guide (ATG) This material was designed specifically for training NOTE: This guide is current through the publication date. Since changes purposes only. Under no may have occurred after the publication date that would affect the accuracy circumstances should the of this document, no guarantees are made concerning the technical contents be used or cited as accuracy after the publication date. sustaining a technical position. The taxpayer names and addresses shown in this publication are hypothetical. They were chosen at random from a list of names of American colleges and universities as shown in Webster’s Dictionary or from a list of names of counties in the United States as listed in the U.S. Government Printing Office Style Manual. www.irs.gov Training 5767-001 (08-2004) Catalog Number Accuracy - Related Penalties For Taxpayers Involved In Tax Shelter Transactions Audit Technique Guide TABLE OF CONTENTS Chapter 1 - Introduction..................................................................................................1 Coverage.......................................................................................................................1 Overview1 Focus .................................................................................................................... ...