The Ninth Circuit, in Taylor v. Commissioner, affirmed the district court's dismissal of a tax preparer's refund action that sought review of preparer penalties assessed for the understatements of his clients' tax liabilities. The district court held that the taxpayer's failure to timely comply...

This article examines the factual background of Loving v. IRS, the invalidated return preparer regulations, and the statute that the IRS relied on as authority. It reviews the district and circuit court opinions and discusses the options available to the IRS to regulate the tax return...