Neil M. Baizer v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
1Opinion of the Court
THOMAS, Circuit Judge:
This appeal requires us to decide, inter alia, whether the Department of Treasury has the authority to impose tax penalties as a result of prohibited transactions with a qualified pension plan when the Department of Labor has entered into a consent judgment concerning the plan. We conclude that, under the circumstances presented in this case, the Department of Treasury possesses such authority and affirm the judgment of the Tax Court.
I
Neil Baizer was an officer and a director, and shareholder, in the Cohen & Baizer Accountancy Corporation (“the accounting firm”). On…
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