3rd Circ. Says Bad Tax Advice Can Nix Some IRS Penalties
By Matthew Villmer
Law360, New York (May 13, 2014, 5:12 PM ET) -- The Third Circuit on Tuesday reversed a lower court's decision to impose a $1 million late tax payment penalty on a deceased wealthy man's grandchildren, saying the heirs may argue they should not be penalized for the mistakes of their tax attorney.
In a unanimous opinion, Judge Thomas L. Ambro said the district court misapplied U.S. Supreme Court precedent when it found the heirs of Sir John R.H. Thouron could not dodge the million-dollar late payment penalty because they allegedly relied on advice of their tax...