The Court appears to reach the conclusion that the Court will just keep sending the case back to the IRS for reconsideration via a Remand when the IRS fails to adequately support its findings, or ultimately abuses its discretion. The key question here is: how many times will Congress, and the Court allow the IRS to keep getting the determination wrong? At some point, reason suggests that the Court will have to make a real determination on whether the IRS erred in their determination and order an appropriate remedy to redress the wrong, or the Court’s review under I.R.C. § 7623(b)(4) will be meaningless.Read More
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In this blog we (i) explore the Scope of Review (i.e. Quantity – what the court looks at) and the Standard of Review (i.e. Quality – how the court evaluates) that the Tax Court set in their 2018 Kasper decision and (ii) explore potential statutory changes.Read More