More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more
7/19/2024
/ Administrative Authority ,
Administrative Procedure Act ,
Chevron Deference ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Government Agencies ,
IRS ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
Statute of Limitations ,
Statutory Interpretation ,
U.S. Treasury