WebApr 13, 2024 · The IRS disregarded those instructions and having found Ahmed ineligible for a deposit under Code Sec. 6603, posted the remittance in satisfaction of Ahmed’s liabilities, and the Tax Court dismissed his appeal as moot. On appeal, the U.S. Court of Appeals for the Third Circuit reviewed the IRS’ treatment of Ahmed’s remittance.WebThe IRS argued that (1) “assessable penalties” should be read broadly to include any penalties in the Code that are not subject to the Code’s deficiency procedures; (2) “taxes” in IRC Section 6201 is broad enough to encompass IRC Section 6038 penalties; and (3) legislative history supports the IRS’s position. Ruling. The Tax Court ...
Tax Court Rules IRS Cannot Assess Certain International …
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Court rules California charter cities can implement sugary drink tax …
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