Robert M. Russell was quoted in a recent Tax Notes article entitled “LB&I Campaigns Aim to Advise Taxpayers, Not Increase Audits,” published on January 29, 2021. Russell observes that some LB&I compliance campaign treatment streams have raised questions from taxpayers.
The article notes:
Robert Russell of Kostelanetz & Fink LLP noted that some clients that have received soft letters regarding different campaign-related issues have asked whether receiving those letters “automatically means that the IRS knows that there is something wrong with their return.”
“Not necessarily,” Nyman said, explaining that it depends on the soft letter and the taxpayer’s facts and circumstances. For example, he said some letters are directed at a taxpayer that has taken a particular filing position and are merely requesting additional information, while others may inform on a potential issue or suggest a course of action.
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