Sarah M. Raben
Subscribe to Sarah M. Raben's PostsSarah M. Raben focuses her practice on private client matters with particular experience in tax controversy. Prior to joining McDermott, she worked for the IRS Office of Chief Counsel. Read Sarah Raben's full bio.
Late CDP Petitions May Still Be Entitled to Tax Court Review
By Andrew R. Roberson and Sarah M. Raben on Apr 22, 2022
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, Trial Courts
In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and held that the 30-day time limit to file a petition with the Tax Court in a...
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District Court Vacates, Sets Aside IRS Reportable Transaction Notice
By Andrew R. Roberson, Jenny L. Johnson Ware and Sarah M. Raben on Mar 23, 2022
Posted In Appellate Courts, Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts
The fallout from taxpayer challenges to the Internal Revenue Service’s (IRS) “reportable transaction” regime continues. On March 21, 2022, the district court in CIC Servs., LLC v. IRS ruled in favor of the taxpayer, vacating Notice 2016-66 and ordering the IRS to return all documents and information produced pursuant to Notice 2016-66 to taxpayers and material...
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Sixth Circuit Sides with Taxpayer in APA Challenge to Reportable Transaction Regime
By Sarah M. Raben, Andrew R. Roberson and Jenny L. Johnson Ware on Mar 7, 2022
Posted In Appellate Courts, IRS Appeals
We previously posted about the US Supreme Court’s opinion in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. In that post, we noted the district court opinion in Mann Construction, Inc. v. United States, No. 1:20-cv-11307 (E.D. Mich. 2021), holding that an IRS Notice...
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