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The U.S. Court of Appeals for the Sixth Circuit’s recent decision in Mann Construction concludes that the civil penalties at issue could not be imposed against the taxpayers because the IRS failed to comply with the notice-and-comment procedures of the APA. Such ruling could result to taxpayers having to face more challenges in the future with the IRS notices, guidance, and regulations that have failed to adhere with APA’s strict requirements.
The disputed centered on a listed transaction.
Read here for the details of the case and the court ruling which reversed the federal court’s decision in favor of the taxpayers: Mann Const. Inc. v. U.S., No. 21-1500 (6th Cir. March 3, 2022)
Mann Construction, Inc. v. United States, No. 21-1500 (6th Cir. 2022) __ Justia
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