A guest blogger has made available for download their article, “Confusion Over Attorney’s Fees in Ninth Circuit Stems from Statute and Regulation…” published on Procedurally Taxing blog. The article begins as follows:
As Keith discussed here, the Ninth Circuit recently issued its opinion on Tung Dang and Hieu Pham Dang v. Commissioner, T.C. Memo. 2020-150. By finding the plaintiffs ineligible for an award of administrative and litigation costs, the court brought closure to the Dangs’ final pursuit of attorney’s fees. Yet, in doing so, it created some confusion (in its majority opinion) and clarity (in its concurrence) and provided another reason why the statute and regulation involving the recovery of administrative costs from administrative proceedings should be changed.
To see the full article, click here: “Confusion Over Attorney’s Fees in Ninth Circuit Stems from Statute and Regulation…”
Posted by Mallory Wentz, Associate Editor, Wealth Strategies Journal.