The U.S. Court of Federal Claims ruled against a recent IRS motion on the pleadings regarding late payment penalties assessed by the IRS against the Estate of Morton Liftin. The Estate claimed a refund, arguing that the late filing of the tax return was reasonable because it had relied in good faith on expert advice concerning a question of substantive tax law. The Court denied the IRS's motion based on these facts.
See Estate of Liftin v. U.S., No. 10-589 T (C.O.F.C. Nov. 8, 2011).
Posted by Andrew Hodes, Associate Editor, Wealth Strategies Journal.
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