a friend of mine just received an IRS notice under section 6677 regarding an account he failed to file the appropriate paperwork for.
Not sure of the circumstance...could be form 3520...not too sure.
Anyway, he made the first disclosure some time ago and that started the ball rolling....
It seems that, due to the value of the account in question, he is going to ask for the penalty as hiring an Accountant to tabulate the back forms will cost more than they can penalize him under code 6677!!...
Has anyone heard of this before?
He is going to outline the full details on the Isaac brock society webpage.
Internal revenue code 6677
Moderator: Mark T Serbinski CA CPA