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For example, in an attachment to the LMSB memo (and in a shorter form in the SB/SE excise tax memo) the Service suggests questions for examiners to ask taxpayers in connection with potential preparer penalties, including: The LMSB and SB/SE memoranda address preparer penalties under Secs. This latter directive is likely being followed by most LMSB agents, but it is interesting to note the frequency with which certain agents use Form 3996 initially without trying to obtain the document internally. |
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