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Weekly IRS Roundup June 5 – June 9, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more

Tax Court Tells IRS It Cannot Assess or Collect Certain Tax Penalties

On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more

IRS Proposes New Regulations to Settle Supervisory Approval of Penalties Requirements

The Internal Revenue Service (IRS) has proposed regulations to clarify the rules regarding supervisory approval of federal civil tax penalties under IRC Section 6751(b). Since Chai v. Commissioner, there has been a...more

Courts Split on Supervisory Approval Requirement for Tax Penalties

Since Chai v. Commissioner, an opinion by the US Court of Appeals for the Second Circuit subsequently followed by the US Tax Court in several opinions, there has been a substantial number of cases litigating issues involving...more

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