Taxpayers can question IRS about possible bad faith

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Taxpayers can question IRS about possible bad faith

Ralph Cunningham
June 26 2014
supremecourtus100x90.jpg

Taxpayers can question the US Internal Revenue Service (IRS) about why it has issued a summons if they have reason to believe that bad faith was involved.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsUnited StatesTax DisputesNorth America Jurisdictions
Cunningham, Ralph BW.jpg
Ralph Cunningham
Contact
Ralph Cunningham worked at ITR between 2004 and 2018 and is now a freelance journalist.
more across site & shared bottom lb ros

More from across our site

Direct Tax
Artificial intelligence
AI in tax: what’s the direction of travel?
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
Russell Gammon, July 01 2025
Direct Tax
Lewin Higgins-Green -- FTI Consulting.jpg
Five minutes with…Lewin Higgins-Green, FTI Consulting
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
July 01 2025
Direct Tax
US Canada trade
Canada to scrap DST in bid to resume US trade negotiations
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
Sam Sholli, June 30 2025
Direct Tax
Parliament House Canberra
PwC Australia’s government contract ban should be extended, senators say
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Tom Ravlic, June 30 2025
Transfer Pricing
Global digital
DSTs as digital infrastructure: the tax challenges of emerging markets
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
Neil Kelley, June 27 2025
Direct Tax
scott bessent.jpg
Pillar two taxes won’t apply to US companies: US Treasury secretary
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
Sam Sholli, June 27 2025
Direct Tax
PwC.jfif
This week in tax: PwC Australia’s tax function generates A$475m amid tumbling 2024 profits
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Sam Sholli, June 27 2025
Transfer Pricing
Nigeria India
Nigeria and India unite in bid to ‘tackle abusive TP’
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
Sam Sholli, June 26 2025
Transfer Pricing
farhan azeem resized.jpg
Five minutes with…Farhan Azeem, PKF Littlejohn
The UK accountancy firm’s transfer pricing lead tells ITR about his expat lifestyle, taking risks, and what makes tax cool
June 26 2025
Direct Tax
uksc-court-sittings-2023.jpg
EY client fails in ‘£16m’ UK Supreme Court tax claim
Dolphin Drilling intends to discuss the final liability amount and manner of settlement with HM Revenue and Customs
Sam Sholli, June 25 2025
Gift this article