WebTAX NOTES, MAY 14, 2024 1001 tax notes® VIEWPOINT Pre-Enforcement Challenges and the Anti-Injunction Act by Patrick J. Smith I. Background The decision by the U.S. District Court for the Western District of Texas in Chamber of Commerce1 has received a substantial amount of attention in the tax world, both for the court’s holding that the WebNov 10, 2024 · First, most lawsuits that try to stop collection action will be dismissed under the Tax Anti-Injunction Act. Sponsored ... Steven Chung is a tax attorney in Los Angeles, California.

Civil Court Remedies for Sovereigns: Taxation - SEDM

WebIn brief. In CIC Services, LLC, v.Internal Revenue Service, 141 S. Ct. 158 (2024), the US Supreme Court addressed the application of the Anti-Injunction Act (AIA) to the reporting requirement and associated penalties applicable to a material advisor with respect to a “transaction of interest.”The advisor in the underlying case had brought suit under the … WebPenalty v. Tax, and the Anti-Injunction Act. The penalty or tax argument also interacts with the debate centering on the Anti-Injunction Act (“AIA”). The AIA states that a court may … cricket alpine rockford il

N HE Supreme Court of the United States

WebThe Supreme Court has held (CIC Services, LLC v.IRS, et al.) that a suit to enjoin Notice 2016–66 does not trigger the Anti-Injunction Act (AIA), even though violating the notice … Webis, a tax designed mainly to influence private conduct, rather than to raise revenue. The Anti-Injunction Act draws no distinction between regulatory and revenue-raising tax laws, Bob … WebThe Supreme Court has indicated that the purpose of the AIA is to protect “the Government’s ability to collect a consistent stream of revenue, by barring litigation to enjoin or otherwise … buderus foutcodes