No Rapid Appeal on Tax Penalty Approval Issue in Land Deal Case

The U.S. Tax Court denied a partnership’s request to quickly appeal the court’s finding that the IRS had met procedural requirements for imposing three tax penalties.

Belair Woods LLC asked the court for special permission to pause its case and appeal a Jan. 6 decision that an agency supervisor properly approved multiple tax penalties. The decision strongly divided the Tax Court’s judges, with seven signing onto at least one of two dissents.

But the Tax Court was unpersuaded with respect to the quick appeal, pointing to remaining questions in the case surrounding whether Belair was entitled to claim a charitable ...