Law360
In an article published July 2, 2018 by Law360 examining the top federal cases in 2018, attorney Kevin Sweeney discusses the opinion in Marinello v. U.S, in which the U.S. Supreme Court invalidated a catchall provision of the tax code known as the omnibus clause.
“It held that, for Section 7212(a) charges, the government must prove a nexus between the conduct at issue and a pending or reasonably foreseeable administrative proceeding,” he said. “In so doing, the court left open the issue of when a proceeding may be reasonably foreseeable.” Subscribers to Law360 may read full article here.