Sefton v. Commissioner of Internal Revenue (IRS) U.S.T.C Docket No. 3789-18 L
Jan 17, 2020OUTCOME: Order Decision for Client-Taxpayer: $0 Owed to IRS on IRS Claim for $3,676,008.73.
IRS made a Restitution Based Assessment ("RBA") against Taxpayer of $8,749,649, which Taxpayer had agreed to and paid in full. However, based upon a General Counsel Memorandum and the Internal Revenue ... Manual, IRS assessed penalties and interests of at least $3,676,008.73 on the RBA. After IRS refused to abate the penalties and interests, Taxpayer filed a Petition in the United States Tax Court challenging IRS authority to charge ANY penalties and interests on RBA assessments. IRS Office of Chief Counsel agreed with Taxpayer's attorney Scott C. Lucas and stipulated to entry of an Order and Decision that Taxpayer owed $0, entered on January 17, 2020.
