Inland Revenue has secured a massive $18.4 million penalty against a woman it accused of promoting tax dodges to clients.

Dior Jay Sabatini, formerly known as Denise Anne Clark, is the second person held accountable for the penalty. Inland Revenue was not able to comment on its chances of recovering the sum.

The penalty imposed on Sabatini at Nelson High Court comprised about $6.4m for the original offences and about $12m in "late payment penalties and interest", plus costs.

Sabatini was a business associate of former Australian Tax Office official Nikytas Nicholas Petroulias.

READ MORE: IRD whacks dodge scheme promoters

​Inland Revenue spokesman Pete van Schaardenburg said Petroulias had been found "jointly and severally liable" for the same penalty after proceedings by him against Inland Revenue were struck out in 2013.

Sabatini had said she had only a junior administrative role with the organisation which ran the scheme that Inland Revenue had objected to, and said the penalties against her were "plucked out of the air".

Inland Revenue gained the power to prosecute people who promoted tax dodges or "abusive tax schemes" to clients in 2003.

In 2012, the Institute of Chartered Accountants expressed some unease about how far down the chain it might go in bringing such prosecutions, saying accountants, like anyone else, could be sucked in by scams devised by others.

Van Schaardenburg said he could not comment on Inland Revenue's prospects of recovering the sum from the pair as that would breach privacy. But he said it would "pursue all practical avenues available to recover money in such a case on behalf of taxpayers."