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Chengwen Tse

Chengwen Tse is an associate in Baker McKenzie’s San Francisco office and a member of the Firm’s Tax Practice Group.

On 21 January 2021, the Tax Court decided Adams Challenge (UK) Ltd. v. Commissioner, 156 T.C. No. 2, 2021 BL 19487 (2021), denying deductions to a foreign corporation because it filed its returns after the IRS had prepared returns on its behalf. Adams Challenge disputed Treas. Reg. § 1.882-4(a)(3)(i), requiring “timely” returns for a foreign corporate taxpayer to claim deductions and credits.

In brief The US Tax Court recently decided two cases further interpreting section 6751(b) procedural requirements requiring supervisory approval for assessing penalties. Section 6751(b)(1) provides that “no penalty under [the Internal Revenue Code] shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the…