EFTA02451491

From: jeffrey E. <[email protected]> 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> The information contained in this communication is confidential,=may be attorney-client privileged, may constitute inside information, a=d is intended only for the use of the addressee. It is the property of<=r>JEE Unauthorized use, disclosure or copying of this communication =r any part thereof is strictly prohibited and may be unlawful. If you h=ve received this communication in error, please notify us immediately b= return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communica=ion and all copies thereof, including all attachments. copyright -all r=ghts reserved EFTA_R1_01551002 EFTA02451491