The Fourth Circuit in Cook v. United States held that federal tax penalty assessments and the payments the debtor made were not voidable fraudulent transfers that generally allow debtors to
Continue Reading 4th Circuit Holds Tax Penalty Obligations Are Not Voidable Fraudulent Transfers
In CIC Services, LLC v. IRS,1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act
Continue Reading Court Invalidates IRS Notice 2016-66 on Micro-Captive Transactions, the Second Time an IRS Notice Was Vacated This Month
On March 3, 2022, the U.S. Court of Appeals for the Sixth Circuit ruled in Mann Construction, Inc. v. U.S.1 the IRS must follow the Administrative Procedures Act (APA)
Continue Reading 6th Circuit Rules IRS Must Follow Administrative Procedures Act in ‘Listing’ Transactions, Raising Questions on Extent of Case’s Application