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Stanley Battat, et ux., Petitioners v. Commissioner of Internal Revenue
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April 27, 2026
Justices Won't Hear Couple's IRS Penalty Approval Fight
The U.S. Supreme Court denied a couple's challenge to a $345,000 penalty against them Monday, preserving an Eleventh Circuit decision rejecting their argument that the IRS didn't get sufficient supervisory approval for the penalty.
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April 06, 2026
IRS Gets Penalty Approval Wrong, Justices Told
The Internal Revenue Service has improperly interpreted a requirement that an agency supervisor must approve tax penalties before they're asserted against a taxpayer, a couple told the U.S. Supreme Court, urging it to overturn an Eleventh Circuit decision slapping them with $345,000 in accuracy-related penalties.
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March 24, 2026
Tax Penalties Didn't Need Early Approval, Justices Told
A lower-ranking IRS agent was allowed to tell a couple, before getting her supervisor's approval, that she recommended they pay tax penalties, the federal government told the U.S. Supreme Court in urging it to uphold the Eleventh Circuit's reading of a supervisor sign-off requirement.