Statutory Guidelines [Appendix A(6) Revenue Procedure 93-34] regarding rules under which a designated settlement fund described in section 468B(d)(2) of the Internal Revenue Code or a qualified settlement fund described in section 1.468B-1 of the Income Tax Regulations will be considered "a party to the suit or agreement" for purposes of section 130.
Washington Revenue Procedure 93-34
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84-35 doesn't apply to S corps. In addition to these factors, your client must demonstrate reasonable cause for consideration of abatement of the penalties. Rev Proc 84-35 states that if ?reasonable cause? can be shown, then they may abate the penalty.
You may qualify for penalty relief if you demonstrate that you exercised ordinary care and prudence and were nevertheless unable to file your return or pay your taxes on time. Examples of valid reasons for failing to file or pay on time may include: Fires, natural disasters or civil disturbances.
Revenue Procedure 84-35 Reasonable cause for failure to file a timely and complete partnership return will be presumed if the partnership (or any of its partners) is able to show that all of the following conditions have been met: The partnership had no more than 10 partners for the taxable year.
The failure-to-pay penalty is one-half of one percent for each month, or part of a month, up to a maximum of 25%, of the amount of tax that remains unpaid from the due date of the return until the tax is paid in full.
Revenue Procedure 84-35 Each partner during the tax year was a natural person (other than a non-resident alien), or the estate of a natural person. Each partner's proportionate share of any partnership item is the same as his proportionate share of any other partnership item.
93-27 defines a profits interest as a partnership interest ?other than a capital interest,? and a capital interest is, in turn, an interest that would ?give the holder a share of the proceeds if the partnership's assets were sold at fair market value and then the proceeds were distributed in a complete liquidation of ...