July 19, 2018
Dear Friends and Colleagues,
It has long been settled law that a taxpayer challenging a tax deficiency assessed by the Internal Revenue Service in federal district court is required to “pay first and litigate later.” While taxpayers can obtain pre-payment review of such deficiencies in Tax Court, a recent decision by the United States Court of Appeals for the Second Circuit in Larson v. United States applied the so-called “full-payment rule” to preclude any judicial review of a civil penalty in excess of $60 million. In my latest New York Law Journal article, "The Full-Payment Rule Strikes Hard: A Look at a Recent Decision," I discuss this decision, its application of the full-payment rule, and potential impact on taxpayers.
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