Article Title

Federal Income Taxation


Andrew Todd

Publication Date


Document Type

Survey Article


In 2022, the United States Court of Appeals for the Eleventh Circuit issued two published opinions involving U.S. federal income tax issues. The first opinion, Sarma v. Commissioner, addressed procedural issues arising under the unified partnership audit procedures that were added to the Internal Revenue Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). The second opinion, Kroner v. Commissioner, addressed an issue of first impression in this circuit concerning supervisory review of tax penalties. This Article surveys both of those opinions.