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September 2, 2021

Treasury regulations limiting economic-hardship exception to individuals reasonably interpret the IRC, 10th Circuit affirms

Affirming the Tax Court, the Tenth Circuit has held (Seminole Nursing Home, Inc. v. Commissioner) that a Treasury regulation restricting the economic-hardship exception under IRC Section 6343(a)(1)(D) to individual taxpayers is a "reasonable interpretation of an ambiguous statute."