UNCONFLICTED

June 5, 2014

  • 220 Internal Revenue
  • 220XXXI Penalties and Additions to Tax
  • 220XXXI(B) Grounds and Amount
  • 220k5219.10 k. Reasonable Cause.

220 Internal RevenueWhen 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.