Mills, Darren J.
The tax court swings back penalties under section 6038(b)(1) / by Darren J. Mills
In this article, Mills examines the recent decision in Mukhi, in which the Tax Court reasserted its determination that the IRS lacks authority to assess information reporting penalties under section 6038(b), and he argues that taxpayers should consider filing protective claims to preserve their right to a refund.
TRIBUNALES
SANCIONES
RECLAMACIONES Y RECURSOS
Tax Notes International 1048-3306 v. 117, n. 4, January 27 2025, p. 581-586
The tax court swings back penalties under section 6038(b)(1) / by Darren J. Mills
In this article, Mills examines the recent decision in Mukhi, in which the Tax Court reasserted its determination that the IRS lacks authority to assess information reporting penalties under section 6038(b), and he argues that taxpayers should consider filing protective claims to preserve their right to a refund.
TRIBUNALES
SANCIONES
RECLAMACIONES Y RECURSOS
Tax Notes International 1048-3306 v. 117, n. 4, January 27 2025, p. 581-586