In June 2016, William Canada, Jr. took the Internal Revenue Service (IRS) to bankruptcy court and won. Mr. Canada successfully challenged the IRS’s claim for a $40 million penalty, pursuant to IRC §6707, for failing to report tax shelter transactions under IRC §6111. Per IRC §6707, the IRS imposes a penalty on anyone who fails [...]
This is the second article in a series of articles regarding recovering administrative costs and legal fees from the Internal Revenue Service (IRS). This article explains one of the many requirements to recovering administrative costs and legal fees, the “prevailing party” requirement. Our previous blog article describes the other basic requirements. A party seeking to [...]
This is the first article in a series dedicated to recovering administrative costs and legal fees from the Internal Revenue Service (IRS). This article is a starting point for making a claim for administrative costs and legal fees as it describes the basic requirements. On occasion, the Internal Revenue Service (IRS) or one of its [...]