Larry Gibbs comments on the federal civil tax penalty system, a theme at the midyear meeting of the American Bar Association Section of Taxation. Gibbs said the discussion showed “just how blunt a penalty is as an enforcement tool. When you tell a taxpayer that they're facing a penalty, that's not just an economic consequence. What you're telling the taxpayer is that they've done something very, very wrong.” Gibbs continued, “I sincerely hope that we can take a hard look at our penalty system, as was done 20 years ago, and hope that we can move forward.”