Tax Controversy Corner - A Limit on the IRS's Prerogative to Change its Mind: Reliance on a Prior No-Change Letter as a Defense to Penalties
5 Pages Posted: 26 May 2016
Date Written: May 1, 2016
Abstract
This article discusses when a result in a prior IRS audit can be a defense to penalties in a later year. This article reviews the recent decision of Brinks Gilson & Lione v. Comm’r, T.C. Memo. 2016-20, and J.J. Powell, Inc. v. United States, 125 Fed. Cl. 73 (2016), and provides some practice tips for successfully defending against penalties based on a favorable result in a prior audit.
Suggested Citation: Suggested Citation
Brackney, Megan L., Tax Controversy Corner - A Limit on the IRS's Prerogative to Change its Mind: Reliance on a Prior No-Change Letter as a Defense to Penalties (May 1, 2016). Journal of Passthrough Entities, Forthcoming, Available at SSRN: https://ssrn.com/abstract=2783791 or http://dx.doi.org/10.2139/ssrn.2783791
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