In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties.
Continue Reading Tax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
Civil Tax Penalties
Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding
By Fox Rothschild LLP on
Recently, the written supervisory approval requirement of Section 6751(b) has been one of the primary issues in Tax Court litigation concerning penalties that the IRS has asserted against taxpayers. The…
Continue Reading Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding