Judicial Appeal of Penalties
Most penalties are subject to judicial review. However, the courts rarely modify assessment of the penalties and interest for underestimate or late payment. No criminal penalties may be imposed by the IRS or Department of Justice except by order of a court upon conviction at trial. Convictions may be appealed within the court system. Prosecution for tax crimes is undertaken in the U.S. District Court having jurisdiction over the taxpayer. Appeal of other tax penalties may be in that district court, in the United States Tax Court, or in the Court of Claims.
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