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United States’ decision in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the IRS’s reportable transaction regime. 6th circuit rejected the IRS’s request to limit vacatur of the Notice to CIC, explaining that vacating the Notice is appropriate
LLC v. IRS,1 the U.S. District Court invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act. Notice 2016-66 prescribed disclosure requirements for taxpayers and material advisors involved in certain micro-captive transactions.
The fallout from taxpayer challenges to the Internal Revenue Service’s (IRS) “reportable transaction” regime continues. On March 21, 2022, the district court in CIC Servs., LLC v. IRS...
The Sixth Circuit opinion in Mann Construction, Inc. v. United States, 2022 WL 619822 (March 3, 2022) is the first step in concluding that the listing of a transaction is not subject to a penalty if the listing did not comply with the Administrative Procedure Act.
For some time, the IRS has "listed" certain transactions as suspect. Based on a recent Sixth Circuit decision, a taxpayer against whom the IRS proposes a penalty for failure to report...