The Sutherland SALT team publishes A Pinch of SALT, a monthly column about hot issues in state and local tax that appears in State Tax Notes. In this month’s A Pinch of SALT, attorneys Marc Simonetti, Zachary Atkins and Madison Barnett discuss jeopardy assessment provisions, which are are intended to protect taxing jurisdictions from taxpayers impeding or escaping the rightful collection of tax. However, the improper use of jeopardy assessments is on the rise, and in this month’s column, we explore this troubling trend and discuss the proper use of jeopardy assessments, the ways they are misused, and practical taxpayer considerations.
Read “Auditors Must Not Use Jeopardy Assessments to Coerce Taxpayers,” reprinted with permission from the April 11, 2011 edition of State Tax Notes.