IRS Approved Tax Penalties Against California Semiconductor Firm

The IRS partially prevailed on Tuesday in proving that its agents followed procedures when seeking approval for penalties assessed against semiconductor provider Microsemi Corp.

Microsemi sued the IRS to redetermine the company’s alleged deficiencies and accuracy-related penalties for tax years 2007 through 2012, as well as an addition for tax year 2008. The IRS responded by moving the Tax Court for partial summary judgment that it complied with IRC Section 6751(b)(1)‘s procedural requirements for assessing penalties.

Section 6751(b)(1) requires that the internal revenue officer responsible for making a penalty assessment first acquire written supervisory approval from their immediate ...