In Green Valley Investors, LLC, Et Al., Bobby A. Branch, Tax Matters Partner, v. Commissioner, the Tax Court on Nov. 9 abated Internal Revenue Code (I.R.C.) § 6662A penalties asserted against four LLCs because Notice 2017-10, which made syndicated conservation easements listed transactions, failed to comply with the Administrative Procedure Act (APA).
U.S. Tax Court Invalidates Conservation Easement Notice, Abates Reportable Transaction Penalty for Failure to Comply with Administrative Procedure Act
