Overview
On April 10, Bloomberg Law quoted Larry Hill in their piece titled, "Treasury Proposes Rules for Supervisory Approval of IRS Penalties." The article discusses the rules in the proposal that clarify that the IRS can get the supervisory approval any time before a pre-assessment notice. Tax professionals weighed in on the matter and generally believe that it is valuable for the Treasury and the IRS to be issuing guidance on penalty approvals given the frequency of litigation on the topic.
Larry Hill noted, "At first blush, it looks like a reasonable attempt to specify rules to avoid the uncertainty that both the government and taxpayers have faced regarding the requirements of supervisory approval." Hill added that hopefully the guidance will help to prevent future litigation. Read the full article at Bloomberg Law (subscription required).
