Sen. Jim Justice (R-W.Va.) and his wife Cathy asked the US Tax Court to block the IRS from collecting a $3.6 million penalty tied to a disallowed $18 million refund claim taken for coal mine reclamation deductions.
Justice, who owns a host of coal, agricultural, and hospitality business ventures, challenged an IRS determination that sustained a levy to collect the penalty—which was assessed for excessive refund claims under IRC Section 6676. The agency improperly concluded the Justices had a previous opportunity to challenge the penalty, barring them from contesting the liability during a later collection due process hearing, according ...
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