DOJ Can’t Reinstate Tax Penalty Invalidated by IRS, Judge Says

A federal judge has ruled that the Justice Department cannot reinstate a $2.4 million tax penalty against an investor after the IRS had already abated it. The court clarified that the IRS maintains the authority to invalidate penalties even after a case is referred to the DOJ.
Why it matters
This decision clarifies the jurisdictional boundaries between the IRS and the Department of Justice regarding tax enforcement and penalty management.
A federal judge won’t allow the Justice Department to revive a $2.4 million tax penalty against a foreign debt investor because the IRS had previously abated it.
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