Kostelanetz LLP has filed an amicus brief on behalf of the Center for Taxpayer Rights in support of petitioner Philip G. Groves in Groves v. Commissioner, T.C. No. 9974-22L, a case involving the IRS’s assessment of tax penalties. The petitioner is challenging penalty liability on the ground that the IRS did not give notice of the penalty computation as required by I.R.C. § 6751(a). While Groves involves tax shelter promoter penalties, its core issue is much broader and highlights that the notice of a penalty computation requirement is essential to fairness and effective tax administration. Kostelanetz argues that penalty computations are necessary to allow taxpyaers to evaluate the accuracy of the penalty and further requires the IRS to “show its work” and to catch its own mistakes before making assessments.
The Kostelanetz team included Megan L. Brackney, Andrew Weiner, Maxwell Brown, and Liz Grant.
