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Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification | Holland & Knight LLP

Published: September 1, 2022

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP)...

Source: jdsupra.com

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