Does Due Process Require More Than Refund Jurisdiction Over Tax Promoter Penalties?
Kostelanetz attorneys Megan L. Brackney, Victor Suthammanont, and Gray Proctor co-wrote an article for Tax Notes Procedurally Taxing blog titled “Does Due Process Require More Than Refund Jurisdiction Over Tax Promoter Penalties?” In the article, they discuss tax shelter promoter penalties under §6700 and how the imposition of promoter penalties