In First-Impression Case, 11th Circ. Clarifies Approval Process for IRS Tax Penalties
"It may be wise for the IRS, as it currently does, to have a supervisor approve proposed tax penalties at an early juncture—long before they are assessed. But the text of the statute does not impose an earlier deadline."
September 15, 2022 at 02:50 PM
4 minute read
Cases and Courts
Until now, the U.S. Court of Appeals for the Eleventh Circuit has not weighed in on the questions of what Internal Revenue Service supervisors may approve and when they may approve it.
In a Sept. 13 opinion, the appeals court reversed a decision by the U.S. Tax Court that prohibited the IRS from applying a penalty against an individual who failed to report nearly $25 million in income. The lawsuit against the IRS was filed in October 2020, following years of deliberation between parties involving unreported cash transfers going back to 2005, according to the opinion.
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