Does Loper Bright Provide a Reason To Rethink Reasonable Cause? (Tax Notes)
In this article for Tax Notes, Jones Day’s Justin Campolieta and Michael Coravos argue that regulations limiting the reasonable cause defense for information reporting penalties may be invalid under Loper Bright, and they explain why the traditional all-facts-and-circumstances approach to reasonable cause should prevail.
Reprinted with permission from the May 36, 2025 issue of Tax Notes. © Tax Analysts 2025. Further duplication without permission is prohibited. All rights reserved.
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