Partner Michael Landman authored the Law360 article, “2 Rulings Highlight IRS’ Uncertain Civil Fraud Penalty Powers,” examining the growing legal scrutiny surrounding the IRS’s authority to administratively impose civil fraud penalties. The article explores how the Supreme Court’s decision in SEC v. Jarkesy casts doubt on the agency’s enforcement powers and highlights a federal court’s finding in U.S. v. Sagoo that such penalties infringed upon a taxpayer’s Seventh Amendment right to a jury trial.
A former tax attorney at the Department of Justice’s Tax Division, Mr. Landman is regarded as a thought leader in white collar defense and government investigations, with articles published in Law360, Daily Journal, and Chambers and Partners Global. He is a recipient of Bloomberg Law’s coveted award, They’ve Got Next: The 40 Under 40, as well as being recognized by Benchmark Litigation and the Global Investigations Review on a historic trial win in U.S. v. Lynch and Chamberlain.
Read the full article here.
