Former Manager Gave Agent Supervisory Approval for Penalties (1)

Nov. 23, 2021, 9:28 PMUpdated: Nov. 23, 2021, 9:56 PM

A former manager who continued to supervise a promoted IRS revenue agent on an ongoing exam concerning a tax deduction of more than $80 million was the agent’s immediate supervisor for the purpose of approving penalties, the U.S. Tax Court ruled.

The Tuesday decision ruled out at least one avenue for Sand Investment Co. LLC to cut penalties tied to its claimed deduction for donating a conservation easement, where a property owner gives away development rights for conservation purposes. The ruling is the latest in a series of clarifying decisions on tax code Section 6751(b)‘s requirement to obtain supervisory ...

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