IRS Clarifies Position on Gross Valuation Penalty

IRS Clarifies Position on Gross Valuation Penalty

News story posted in Email Chief Counsel Advice on 17 January 2012| comments
audience: National Publication | last updated: 17 January 2012
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Summary

In Email Chief Counsel Advice, the IRS has stated that so long as property qualifies for a charitable deduction, there is no reasonable cause/good faith exception with respect to the 40% gross valuation penalty. 

ECC 201202026

Full Text:

UILC: 6664.03-00
Release Date: 1/13/2012

ID: CCA_2011122108424964

Office: * * *

From: * * *
Sent: Wednesday, December 21, 2011 8:42:51 AM
To: * * *
Cc:
Subject: FW: 6662(h) penalty post-Aug 17, 2006

So long as it is charitable deduction property, I agree that there is no reasonable cause/good faith exception with respect to the 40% gross valuation penalty.

I wouldn't have a lot to say about the penalty, but I could talk about it just a little. 

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