People
Practices
Industries
Advisory Services
Thought Leadership / News
Diversity & Inclusion
Our Firm
Offices
Careers
Stay in Touch
People
Practices
Litigation
ADR
Appellate Law
Civil Litigation
Class Actions - Mass Torts
Commercial Litigation
Construction Litigation
Corporate Restructuring & Bankruptcy
Crisis Readiness & Response
Eminent Domain & Condemnation
Energy Litigation
Government Investigations and Compliance
Insurance Law
Intellectual Property
Labor & Employment
Real Estate Litigation
Tax Controversy & Litigation
Compliance
Blockchain and Digital Assets
Cybersecurity, Data Management and Data Privacy
Government Investigations and Compliance
Healthcare
Transactional
Banking & Finance
Blockchain and Digital Assets
Capital Markets & Securities
Construction Transactions
Energy Transactions
Healthcare Transactions
Insurance Law
Intellectual Property
Labor & Employment
Mergers & Acquisitions
Private Equity
Real Estate Transactions
Tax Planning
Families & Individual
Family Law
Estate Planning
Probate and Estate Administration
Probate and Fiduciary Litigation
Industries
Agriculture
Construction
Energy
Family Office & Family Business
Franchising
Healthcare
Hospitality
Real Estate
Technology
Gray Reed Website works best with JavaScript enabled.
Thought Leadership / News
Print
PDF
Email
Related Practice
Taxation
Related People
Joshua Smeltzer
Spring 2021
Thought Leadership
Questioning IRS Approval of Penalties Under Code Sec. 6751
Journal of Tax Practice & Procedure
By
Joshua D. Smeltzer