The fallout from taxpayer challenges to the Internal Revenue Service’s (IRS) “reportable transaction” regime continues. On March 21, 2022, the district court in CIC Servs., LLC v. IRS ruled in favor of the taxpayer, vacating...more
We previously posted about the US Supreme Court’s opinion in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. In that post, we noted...more
The Internal Revenue Service (IRS) Chief Counsel is the chief legal advisor to the Commissioner of Internal Revenue on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Laws....more
1/27/2022
/ Administrative Procedure Act ,
Appeals ,
Enforcement ,
Government Entities ,
IRS ,
Large Business & International Division (LB&I) ,
Self Employed ,
Small Business ,
Tax Court ,
Tax Exempt Entities ,
Tax Litigation ,
U.S. Treasury
In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime....more
6/1/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties