Appeals & Tax Court Petitions

Sec. 6752(1)(b) was satisfied by an IRS supervisor’s timely signed approval of penalties against the taxpayer, without any “meaningful review” or “reasoned decision-making,” the Tax Court held.

Second Circuit holds Sec. 6213(a) deadline is nonjurisdictional.

The court granted the IRS’s motion because the petition was untimely and denied the taxpayer’s contending that the Service’s deficiency notices were invalid.

Although the deadline for filing a challenge to an IRS employment status determination is nonjurisdictional, an employer’s facts did not warrant equitable tolling, the Tax Court held.

A handwritten signature was not required on a petition filed with the Tax Court that was created on the court’s online petition generator.

Reversing the Tax Court, the appellate court held the statute gives the IRS authority to assess the penalties for failing to file information returns disclosing ownership in foreign corporations.