Taxpayer integrity in US law enforcement practice.

Abstract

The subject of the study is the concept of taxpayer integrity in the US law enforcement practice, in particular, the approach of the US tax authorities and the US Tax Court in applying this concept when considering tax disputes. When considering this issue, it was revealed that the signs of the taxpayer's integrity are fixed in the US Internal Revenue Code in Article 1.6664-4. In accordance with the provisions of this article, no fine may be imposed in accordance with section 6662 in respect of any part of the underpayment if the taxpayer proves that there was a reasonable reason for such part and that the taxpayer acted in good faith. В В В The main conclusion of the study is that the existence of a legal norm defining the signs of a taxpayer's good faith in the US tax legislation allows taxpayers to avoid a fine in case of incomplete fulfillment of tax obligations by providing a reasonable reasonable reason. In addition, we can conclude that when determining the legality of accepting expenses for the purpose of reducing the income tax base, the US Tax Court takes into account the nature of the appearance of these expenses (case Neonatology Assocs., P.A. v. Commissioner - 115 T.C. 43, 99 (2000), aff'd, 299 F 3d 221 (3d Cir. 2002))