Supreme Court Rejects Review of Couple’s IRS Penalty Challenge

The US Supreme Court denied review Monday of a couple’s case focused on the issue of when the IRS needs to get supervisory approval for penalties.

Stanley and Zmira Battat, after a long running tax battle, lose out on a shot to contest their roughly $345,000 in accuracy-related penalties before the court.

IRC Secton 6751(b)(1) requires approval by a supervisor on an initial determination before a penalty is issued by the IRS agent handling a case.

The Battats in their petition argued that a formal IRS written communication that informs a taxpayer that penalties have been determined and that solicits ...