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Expert Analysis

Does A Civil Penalty Time Bar Apply In The Tax Context?

By Armando Gomez, Alan Swirski and Keith Neely (November 27, 2018, 3:18 PM EST) -- Does the Internal Revenue Service have an unlimited period of time to assess penalties against alleged promoters of abusive tax shelters? That's the question posed to the U.S. Court of Appeals for the Seventh Circuit in a potentially pivotal case slated for argument next month: Philip Groves v. U.S.[1] For decades, the IRS has taken the view that promoter penalties imposed pursuant to Internal Revenue Code Section 6700 are not subject to a statute of limitations because the code does not expressly provide for one. Perhaps surprisingly, courts have historically agreed with the IRS.[2]...

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