Frieda Korobkin Leonard Korobkin Leonard Korobkin Professional Corporation v. United States

The Korobkins were allegedly involved in several abusive tax shelter transactions, and were assessed over $300,000 in penalties under I.R.C. § 6700. People who disagree with a penalty assessment can contest it by (1) paying 15% of the assessment and filing an administrative refund claim within 30 days of notice of the penalty, (2) waiting until the IRS denies the claim or until 6 months elapse (whichever is earlier), and (3) filing suit in district court within 30 days after that. I.R.C. §§ 6703(c)(l)-(2). The Korobkins did steps (1) and (2), but waited too long on (3). The district court…