Penalties and Reasonable Cause
Thouron v. United States: Third Circuit Holds Reliance on Counsel may Relieve Penalties for Late Payment of Taxes.
In Thouron v. United States, No. 13-1603 (3d Cir. May 13, 2014) the Court of Appeals for the Third Circuit […]
SCOTUS Struggles with TEFRA Jurisdiction: Oral Arguments in United States v. Woods
On October 9, 2013, the U.S. Supreme Court heard oral arguments in United States v. Woods, 471 Fed. Appx. 320 (5th Cir. […]
Jurisdiction to Dispute Penalties: Partner v. Partnership-Level Proceedings
The U.S. Supreme Court recently heard oral arguments in United States v. Woods, 471 Fed. Appx. 320 (5th Cir. 2012), […]
Did the Tax Court Enforce Retroactive Penalties?
Taxpayers and practitioners alike were unsettled by recent language from a Tax Court opinion suggesting that retroactive penalties may be […]
The Eighth Circuit Weighs in on Whether Outside Basis is an Affected Item at the Partner Level
As a part of the continuing TEFRA partnership audit proceeding litigation saga, the Eighth Circuit in Thompson v. Comm’r, (No. […]