News & Analysis as of

Proposed Regulation Internal Revenue Code (IRC) Tax Court

McDermott Will & Emery

IRS Roundup May 15 – June 2, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025....more

Holland & Hart LLP

5 Things to Know About the IRS Proposed Regulations for Supervisory Approval of Penalties

Holland & Hart LLP on

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

McDermott Will & Emery

IRS Proposes New Regulations to Settle Supervisory Approval of Penalties Requirements

McDermott Will & Emery on

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

Latham & Watkins LLP

US Tax Court Voids Penalties Affecting Syndicated Conservation Easements; Treasury Reacts With Proposed Regulations

Latham & Watkins LLP on

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

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