An IRS agent must obtain a supervisor’s written approval before formally proposing a tax penalty for failing to disclose required information about a transaction, the U.S. Tax Court ruled.
The Thursday ruling came in a case concerning the IRS’s finding that Laidlaw’s Harley-Davidson Sales Inc., a Harley-Davidson dealership, didn’t report its participation in a transaction on time. The decision further clarifies the reach of a supervisory approval requirement under tax code Section 6751(b), a major issue at the court since its landmark ruling in Graev v. Commissioner in 2017.
“We expected that this was a very possible, ...
Learn more about Bloomberg Tax or Log In to keep reading:
See Breaking News in Context
From research to software to news, find what you need to stay ahead.
Already a subscriber?
Log in to keep reading or access research tools and resources.