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Internal Revenue Code (IRC) Final Rules Tax Court

Holland & Knight LLP

Final Regulations on IRS Appeals Issued

Holland & Knight LLP on

In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more

Eversheds Sutherland (US) LLP

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

Holland & Knight LLP

Final Regulations Issued on Penalty Supervisory Approval

Holland & Knight LLP on

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

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