Overview
Steptoe's Lawrence Hill and Richard Nessler co-authored an article for Bloomberg Tax titled, "Ninth Circuit Holds That Supervisory Approval Not Required for §6707A Penalty Until Assessment."
This article discusses the recent case, Laidlaw's Harley Davidson Inc. v. Commissioner where the Ninth Circuit Court of Appeals reversed a decision by the Tax Court and grappled with when written supervisory approval must be provided under section 6751 when the IRS has asserted a section 6707A penalty.
The full article can be read here.
