Explained Disclosure

The qualified amended return regulation (“QAR”) may eliminate the 20% accuracy penalty; however, it will not eliminate the civil fraud penalty. A qualified amended return is an amended return filed after the due date of the return but before certain events (in the context of FBAR issues): (1) the date the taxpayer is first contacted for examination, (2) the date a John Doe Summons is issued to identify the name of the taxpayer.

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