Recent revelations involving documents found to be backdated by the IRS in the case of Lakepoint Land II, LLC v. Commissioner resulted in the Tax Court imposing sanctions on the IRS.
Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - .
Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, .
Decisions from the Ninth and Eleventh Circuits departed from the Tax Court’s analysis of Chai v. Commissioner. In Laidlaw’s Harley Davidson Sales v. Commissioner, the Ninth Circuit applied a textualist approach and held approval is required only before assessment of penalty.