Suzanne Somers’ Estate Fails in Tax Rules Challenge Post-Chevron

Late actress Suzanne Somers’s estate and her surviving husband failed on Tuesday to revive their challenge to a Treasury rule governing tax penalty assessments after the US Supreme Court ending the Chevron doctrine.

Before Somers’s death in October 2023, the couple sued the IRS to contest $2.75 million in combined taxes and penalties attributable to adjustments against their partnership entity, Palm Canyon X Investments LLC.

To combat their liability, Somers and television producer Alan Hamel, her husband, challenged Temporary Treasury Regulation § 301.6231(a)(6)-1T, which permitted penalty assessments after a partnership proceeding regardless of whether partner-level determinations were required. They claimed ...