Posted on Sep 15, 2022 in
Taxation |
Comments Off on Tax Penalty May Be Communicated to Taxpayer Prior to Required Supervisory Approval
In Kroner v. Commissioner, 2022 U.S. App. LEXIS 25650 (11th Cir. Sept. 13, 2022), the court reversed a U.S. Tax Court decision to hold that the Internal Revenue Service (“IRS”) did not violate section 6751(b) of the Internal Revenue Code when it obtained supervisory approval prior to the assessment of a tax penalty, even though the penalty was communicated to the taxpayer prior to...