Partnerships Ask Tax Court to Reconsider IRS Penalty Decisions

Two conservation easement donors want the US Tax Court to reconsider penalty decisions after new evidence from a different case revealed the IRS had backdated its penalty approval forms.

The IRS recently decided to settle and forgo a $15.2 million penalty on LakePoint Land II LLC after it admitted agency employees backdated an approval form and misled the Tax Court about it for months. The supervisor on the case said her initial misrepresentation to the court was an “unintentional error,” and the agency admitted it should have “more fully explained the circumstances surrounding the placement of the date,” but it ...