Humboldt Shelby Holding Corporation v. Commissioner of Internal Revenue

Track this case

Case Number:

23-302

Court:

Appellate - 2nd Circuit

Nature of Suit:

Agency 

  1. 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.

  2. 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.

  3. 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.

  4. June 14, 2023

    Tax Court Wrongly Barred Penalty Challenge, 2nd Circ. Told

    A group of six companies asked the Second Circuit to reverse several U.S. Tax Court decisions in separate cases that blocked them from challenging IRS levies and collection of penalties, saying the penalties weren't properly approved by a supervisor.