Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions.
Key Points:
..Notice 2017-10...more
The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations.
Key Points:
..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more
6/17/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Enforcement ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
The new tax law limits the deductibility of False Claims Act settlements and requires that settlement agreements identify the deductible “restitution” amount.
Settlements under the False Claims Act (FCA), which often...more