@macuser_22 wrote:
Then what is the point (or purpose) of the 709 at all if it can be simply ignored with no tax or penalty. Are you suggesting that it can be ignored since it makes no difference?
I am simply suggesting that a penalty cannot be imposed without statutory authority.
You appear to be arguing that a penalty can be imposed but have not yet cited a Code section that imposes a penalty other than one that is based upon tax due.
You also stated that the lifetime exclusion does not apply unless a 709 is filed (and tax is due as a result) but there is absolutely no authority (that I can find) for that proposition.
