IRS Victory In Easement Case Prompts An Offer To Not Be Refused
The decision that I think likely triggered this notice, which I suspect was prepared some time before, was Plateau Holdings LLC (TC Memo 2020-93). As with many of the decisions Judge Lauber approved of the IRS disallowing on a technical error involving the terms of the easement. But in order to assess the penalty valuation has to be considered and that gets to the heart of the matter.
Why Stimulus For The Dead Might Not Have Been So Bad
Overall I think the IRS did a pretty good job particularly given that they went into this “war” with Vietnam War era software as you can see in this article by Tom Temin in Federal News Network earlier this year. Not to mention a huge headcount reduction in the aftermath of the interminable “scandal”.
GAO seems to be concerned about them chasing the erroneous stimulus payments, but given that many of them went to widows and orphans, I think that should be a low priority.
Bottom line is that when Congress wanted money shoveled out quickly IRS thought fast and made mistakes which in retrospect was absolutely the right thing to do.
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Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.