The 5th U.S. Circuit Court of Appeals has held that an individual who successfully challenged in bankruptcy court a $40 million penalty assessed against him by the IRS wasn’t entitled to recover attorneys’ fees and costs. The individual failed to file his fee petition within 30 days of the final judgment in his favor, and the filing period wasn’t suspended. According to the court, viewing the facts most favorable to him, the taxpayer had until Aug. 7, 2017, to file an application for attorneys’ fees, but he didn’t file the petition until Sept. 14, 2017. (Canada, Jr, 2/20/20)
