On April 11, 2023, the IRS issued proposed regulations concerning IRC § 6751(b). The statute requires that specific civil penalties must be personally approved (in writing) by the immediate supervisor of the individual making...more
The Tax Court has denied Coca-Cola’s request to file an out of time motion for reconsideration of the Court’s November 2020 adverse transfer pricing decision. Coca-Cola filed its motion 196 days after the Tax Court served its...more