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Mann Construction, Inc., et al v. USA
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December 22, 2022
Top Federal Tax Cases Of 2022
During a consequential year, the U.S. Supreme Court allowed a House panel to get former President Donald Trump's tax returns and found the U.S. Tax Court could hear a firm’s day-late challenge regarding a levy it faced. Here, Law360 reviews some of the most significant federal tax decisions of 2022.
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July 01, 2022
Top Federal Tax Cases Of 2022: Midyear Report
Tax regulations' compliance with administrative law was a major theme in notable federal tax decisions in the first half of 2022, while the U.S. Supreme Court revived a law firm's day-late levy challenge in the U.S. Tax Court. Here, Law360 reviews those and other significant tax rulings by federal courts in the first half of the year.
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March 03, 2022
IRS Trust Guidance Violated Admin. Law, 6th Circ. Says
A 2007 IRS notice requiring the disclosure of potentially abusive benefit trust arrangements on pain of penalty violated administrative law because it didn't go through public comment, the Sixth Circuit said Thursday, reviving a construction company's challenge to the guidance.
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February 11, 2022
4 Tax-Related Administrative Procedure Act Cases To Follow
A recent high-profile case in the Eleventh Circuit has once again demonstrated the power of the Administrative Procedure Act in challenges to IRS regulations alleging that the agency didn't follow the law in crafting regulations or other guidance. Here, Law360 looks at the Hewitt case and others that are primed to influence the extent to which the agency's compliance with administrative requirements may affect its ability to enforce its own guidance.
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December 09, 2021
6th Circ. Questions IRS' Guidance Requiring Trust Disclosure
A Sixth Circuit judge Thursday questioned the IRS' authority to issue guidance requiring disclosure of trust arrangements without soliciting public feedback, saying in oral arguments for a construction company's dispute with the agency that its administrative law exemption wasn't obvious.
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August 24, 2021
Construction Co. Shouldn't Get Penalty Refund, 6th Circ. Told
A construction company shouldn't get a refund of penalties for not reporting a kind of benefits trust to the Internal Revenue Service, because the notice requiring it didn't violate administrative law, the agency told the Sixth Circuit.
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June 24, 2021
IRS Guidance On Benefits Trusts An Overreach, 6th Circ. Told
A federal court wrongly dismissed an Ohio construction company's suit against the Internal Revenue Service claiming guidance requiring the disclosure of potentially abusive benefit trust arrangements exceeded the agency's regulatory authority, the company told the Sixth Circuit.