The U.S. IRS has released an international practice unit, Overview of Accuracy-Related Penalties. The general overview of the practice unit is provided as follows: Taxpayers who do not use reasonable care in complying with federal income tax laws may be subject to penalties. Penalties are used to encourage taxpayers to voluntarily comply. If a taxpayer underpays and has no valid defense, penalties will apply. IRC 6662 summarizes penalties related to return accuracy. An accuracy-related penalty can apply to an income, estate or gift tax return. IRC 6751(b)(1) requires that the examiner's immediate supervisor approve the penalty assertion. The supervisory approval...