Top 10 problems taxpayers face with the IRS
![A man walks past the Internal Revenue Service (IRS) headquarters in Washington, D.C., U.S.. Photographer: Andrew Harrer/Bloomberg](https://s32566.pcdn.co/wp-content/uploads/2021/01/IRS_ominious-figure.jpg.optimal.jpg)
International penalties
The IRS’s assessment of international penalties under IRC §§ 6038 and 6038A is not supported by statute, and systemic assessments burden both taxpayers and the IRS. The IRS’s treatment of IRC §§ 6038 and 6038A foreign information reporting penalties as systemically assessable is legally unsupportable and imposes costs, delays and stress for taxpayers.