TAG Tax

Steven Jager of Fineman West, a CPA who is admitted to the U.S. Tax Court, was recently featured in Tax Notes for his recent work on the case Ching Tzu Lu a.k.a. Susan Lu v. Commissioner, No. 10523-23L (T.C. Filed July 1, 2023). The case has received national attention.

As reported by Andrew Velarde of Tax Notes, "After initially preparing to fight, the IRS will instead fully abate a foreign trust penalty against a litigant, leaving unresolved the larger issue of what constitutes written supervisory approval for a foreign trust penalty.”

Velarde continues, "The national taxpayer advocate's 2023 report to Congress identified the IRS’s approach to international information return penalties as one of the most serious problems for taxpayers, labeling it 'draconian and inefficient.' From 2018-2021, the average foreign gift penalty was more than $235,000, it noted. It expressed concern over the IRS’s systemic assessment of the penalties without providing an opportunity for the taxpayer to establish reasonable cause. It also cited Lu in arguing that the IRS’s use of systemic assessments raises legal questions about whether it is meeting section 6751(b) requirements by providing only an AMS notation as proof of supervisory approval.”

The unique resolution of the Lu case and the case being cited in a U.S. Congressional report is evidence of Jager’s strong advocacy skills and his understanding of tax law.

Read the entire article about Steven Jager's case, "With Abatement, IRS Dodges Penalty Approval Query in Lu," as reported by Tax Notes, here.