News & Analysis as of

Criminal Liability Internal Revenue Code (IRC)

Gray Reed

When is an Accountant Forced to Testify Against Their Client?

Gray Reed on

Recently, in a criminal case involving a physician who hired an accountant to prepare and submit certain tax forms to the IRS on her behalf, the court denied attorney-client and work-product privilege claims and ordered the...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

Oberheiden P.C. on

The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

IRS Voluntary Disclosures and Criminal Employment Tax Violations

Freeman Law on

Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more

Freeman Law

IRS Notice 2007-83 Declared Unlawful Under the Administrative Procedure Act

Freeman Law on

The Administrative Procedure Act. The Internal Revenue Code (the “Code”) contains over one hundred different civil penalties for various acts or failures to act. For example, Section 6707A requires taxpayers, in certain...more

Gray Reed

Recent Supreme Court Case Provides Possible Pre-Assessment Judicial Review for Onerous Penalties

Gray Reed on

The Supreme Court’s recent decision in CIC Services, LLC v. Internal Revenue Service may have significantly expanded taxpayers’ ability to obtain immediate injunctive relief against onerous tax reporting requirement....more

Latham & Watkins LLP

US Supreme Court Allows Challenge to IRS Rule to Go Forward Despite Anti-Injunction Act

Latham & Watkins LLP on

The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations. Key Points: ..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more

Holland & Knight LLP

U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits

Holland & Knight LLP on

The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more

McDermott Will & Emery

Supreme Court Opens Door to APA Challenge of Overreaching IRS Information Reporting Regime

In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime....more

Eversheds Sutherland (US) LLP

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC - The Anti-Injunction Act has its limits

On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more

Alston & Bird

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

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Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action....more

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