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On January 13, 2021, the US District Court for the Northern District of Texas ruled in favor of Exxon Mobil Corporation ( Exxon ) in its battle against the government over tax penalties. Exxon filed amended returns for its 2006-2009 tax years seeking a $1.35 billion tax refund based upon a change of character of certain transactions (from mineral leases to purchase transactions). The government disallowed the refund claims and imposed a $200 million penalty pursuant to Internal Revenue Code (IRC) section 6676. Exxon paid the penalty and filed suit for a refund. We have written extensively concerning IRC section 6676, warning taxpayers of this potential landmine. See, e.g., ....
On January 13, 2021, the US District Court for the Northern District of Texas ruled in favor of Exxon Mobil Corporation (“Exxon”) in its battle against the government over tax. ....