From: jeffrey E. <jeevacation@gmail.com>
Sent: Friday, September 9, 2016 10:38 PM
To: Fenn, Patrick
Subject: other things we might consdider including
The taxpayer's education;
Whether the taxpayer has previously been subject to the tax for which =he return has not been filed;
Whether the taxpayer has be=n penalized before;
The level of complexity of a tax or c=mpliance issue.
The tax=ayer complied with tax filing and payment obligations in the past- =AO
r=cently told and then he immediatly filed his previously unfiled retu=ns;
=here was no indication that he had taken efforts to intentionally conceal =he reporting of income or assets; no
tax difference. no =vasion„
In making the reasonable cause argument, it is critically important to analyze the facts, support the facts with affidavits
or other evidence.. these are all questions , should w= attachh affatdavits from preparer, apollo others.=et.c
please note<=r>
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