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Sixth Circuit Invalidates Longstanding IRS Administrative Practice
The Wagner Law Group 
Apr. 21, 2022 "The challenged agency action ... was Notice 2007-83, entitled 'Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies.' ... The plaintiffs ... were penalized for failure to file Form 8886 to report this listed transaction on their tax return.... [T]he issue on which the Sixth Circuit decided the case was the failure of the IRS, in issuing Notice 2007-83, to comply with the notice and comment period requirements of the Administrative Procedure Act." [Mann Construction Inc. v. U.S., No. 21-1500 (6th Cir. Mar. 3, 2022)] MORE >> |
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