Petition of the day

By John Ehrett
on Jun 20, 2015 at 11:00 pm

The petition of the day is:

Issue: 1. Whether the Sixth Circuit improperly held petitioner to a heightened burden in construing the substantive interest provision of 26 U.S.C. § 6611; and (2) whether the Sixth Circuit improperly frustrated petitioner’s right to rely on the Internal Revenue Service’s own published guidance materials.