Understanding The IRC's Excessive Refund Claim Penalty

By Kevin Spencer, Edward Froelich and Samuel Preston (May 2, 2024, 5:46 PM EDT) -- Recently, the Internal Revenue Service has been asserting the Internal Revenue Code Section 6676 penalty much more frequently in examinations and in court. For example, in 2023, a government counterclaim in the U.S. District Court for the Middle District of Georgia sought to recover Section 6676 penalties in Townley v. U.S.[1] And, internal IRS guidance requires examiners to consider whether to assert the penalty in every case in which a refund is disallowed....

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