Bloomberg Law
Aug. 21, 2023, 6:32 PM

NJ Restaurants Can Dispute Penalties From Invalid IRS Notice

Jeffery Leon
Jeffery Leon
Reporter

A company fighting tax penalties for a life insurance policy arrangement that was flagged as a listed transaction under an invalid IRS notice received a mixed ruling from a New Jersey district court.

The court held on Friday that it had jurisdiction to hear Oom Inc.'s refund claims, finding that the company did exhaust its administrative remedies after filing an amended complaint. An Administrative Procedure Act claim by the company was denied due to statute of limitations, as Oom made the claim over six years after the IRS published a key notice in 2007.

In 2019, the IRS began investigating ...

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