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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

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Josh Ungerman was quoted in a Tax Notes article published on Aug.30, 2023

Firm Partner, Josh Ungerman was quoted in a Tax Notes article published on August 30, 2023 written by Kristen A. Parillo, titled "Tax Court Sanctions IRS for Backdated Penalty Approval."  On August 29, the Tax Court vacated an IRS summary judgment win on penalty compliance in a conservation easement case,  "LakePoint Land II LLC v. Commissioner," and awarded attorney fees to the petitioner as sanctions for the agency's failure to alert the court that it had submitted a backdated penalty approval form.  Mr. Ungerman stated the Tax Court's findings in LakePoint "are unfortunate and hopefully isolated to the matter at hand and can be a learning moment."  He added that in his experience, IRS attorneys typically concede penalties when they don't have the necessary documented approval.