New Reg Hurts Taxpayer's Penalty Argument, US Tells 5th Cir.

By David Hansen · January 23, 2025, 4:44 PM EST

Final regulations clarifying that an Internal Revenue Service supervisor can approve tax penalties at any time before the agency issues a deficiency notice undermines an appellant's arguments in a tax dispute,...

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Case Information

Case Title

Swift v. CIR

Case Number

24-60270

Court

Appellate - 5th Circuit

Nature of Suit

Tax Court 

Date Filed

June 03, 2024