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A tax preparer is being targeted for a preparer penalty examination. The IRS initial correspondence with him was vague but they Googled the letter number and found it was for a Preparer Penalty Examination. The IRS asked him to bring all things related to 09&10 from returns to correspondence. §6107 states the preparer only has to keep the documentation for 3 years. The preparer raised this issue and the examiner stated he should keep documents "indefinitely" just in case. The examiner told the preparer in so many words the penalty had already been determined. The preparer smelled a rat, sent in the disclosures for 09&10, cited 6107, but wont go into the meeting. Does the IRS has legal authority in the IRC to impose Preparer Penalties because he didnt attend the ambush?