IRS Must Follow Administrative Procedures Act
U.S. Court of Appeals for the Sixth Circuit ruled in Mann Construction, Inc. v. U.S.1 the IRS must follow the Administrative Procedures Act when identifying listed transactions for purposes of applying the I.R.C. ยง 6707A penalty.
Supreme Court Mann Construction Inc Mayo Foundation For Medical Education Us Court Mann Construction Holding Mayo Foundation
Source: natlawreview.com