Day Stores, Inc. v. Commissioner of Internal Revenue
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February 05, 2024
2nd Circ. Judges Skeptical Over IRS Penalties In $380M Case
Second Circuit judges were skeptical of the IRS' claim during oral arguments Monday that it wasn't required to verify that a supervisor had signed off on penalties for six companies in a $380 million tax scheme case, saying a plain reading of the law seemed to demand it.
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October 18, 2023
Cos. Ask 2nd Circ. To Revive $380M Tax Scheme Penalty Suits
Six companies that collectively owed more than $380 million in tax liabilities stemming from their participation in a tax avoidance scheme were wrongly denied the opportunity to verify that their penalties were properly approved by the IRS, the companies told the Second Circuit.
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September 12, 2023
Tax Court Rightly Barred Penalty Challenge, US Tells 2nd Circ.
Six companies that collectively owed more than $380 million in tax liabilities stemming from their participation in a tax avoidance scheme should not be allowed to challenge whether penalties were properly approved after judgments were entered, the U.S. told the Second Circuit on Tuesday.