Nelson Mullins partner Peter Lowy authored an article for Bloomberg Tax examining a recent Treasury Inspector General for Tax Administration (TIGTA) report that uncovered instances of IRS personnel backdating penalty approvals, resulting in the agency conceding more than $68 million in penalties.

In the article, Lowy explores the legal and ethical implications of backdating, distinguishing between legitimate retroactive agreements and records that misrepresent when actions occurred. He also highlights practical considerations for tax practitioners, including the importance of accurate documentation, verifying approval timelines and identifying potential procedural deficiencies when challenging IRS penalties.

Read the full article: TIGTA Report on IRS Backdating Offers Lessons for Tax Practice