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Rami Khoury’s Latest Article Published by Tax Notes.
August 12, 2026
Taylor Nelson Amitrano LLP is pleased to announce that partner Rami Khoury's latest article, "Proposal to Amend Section 6651(b)(1) to Account for Late Payments in Failure-to-File Penalties," has been published by Tax Notes.
Co-authored with Jin Soo Lee, the article proposes an amendment to IRC Section 6651(b)(1) that would allow late tax payments to reduce the monthly base of the failure-to-file penalty, bringing it into alignment with the computation of the failure-to-pay penalty. The authors explain how this change would encourage voluntary compliance while promoting fairer and more consistent tax administration.
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