Section 6751

Penalties, Section 6751

The IRS Issues Proposed Regulations under Section 6751(b)

By Jason B. Freeman Apr 11, 2023
Penalties, Section 6751

Ninth Circuit Opines on Section 6751(b) and its Application to Assessable Penalties

By Jason B. Freeman Apr 07, 2022
Conservation Easement, Section 6751, Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Oxbow Bend, LLC v. Comm’r | Conservation Easement and “Initial Determination” of Penalties

By Freeman Law Mar 25, 2022
Penalties, Section 6751, Tax Court

Tomato, Toma-toe: IRS’s Imperfect Designation of “Immediate Supervisor” Deemed Insufficient to Overturn Penalties Under Code Section 6751(b)(1)

By Cory Halliburton Jan 27, 2022
Penalties, Section 6751, Tax Court, The-Tax-Court-in-Brief Insights

A Taxpayer Victory on Section 6751(b) Grounds

By Freeman Law Oct 21, 2020
Fraud, Section 6751, Tax Court, The-Tax-Court-in-Brief Insights

The IRS and Fraud Penalties: Recent Case Addresses the Approval Requirement

By Freeman Law Jul 05, 2020
Listed transaction, Penalties, Section 6707A, Section 6751

Tax Shelters, the Reportable Transaction Penalty, and the Graev’ Supervisory Approval Requirement for IRS Penalties

By Jason B. Freeman Mar 17, 2020
Penalties, Section 6751, Trust Fund Penalty

The Tax Court Determines §6672 Penalties are Penalties Subject to §6751(b) Requirements

By Jason B. Freeman Mar 04, 2020
Fraud, Penalties, Section 6751, Tax Court

The IRS Satisfies its Burden of Production under §6751(b) With Signed Penalty Approval Form

By Jason B. Freeman Feb 11, 2020