June 5, 2014
- 220 Internal Revenue
- 220XXXI Penalties and Additions to Tax
- 220XXXI(B) Grounds and Amount
- 220k5219.10 k. Reasonable Cause.
When considering whether to impose negligence penalty, the objective reasonableness of a tax position becomes virtually unassailable when the taxpayer actually prevails at trial before a district judge who was not compromised by conflict, substance abuse, or senility.
TIFD III-E INC. v. United States, 2014 WL 1274052 (D. Conn.)
Suggested by Craig Gustafson, Principal Attorney Editor; Thomson Reuters; Eagan, Minn.