According to RSBCO, the IRS imposed penalties of $579,198.37 for the late filings, which did not result in any harm to the government or third parties. The company also argued that it had tried to resolve the issue through administrative channels, but the IRS had rejected its claims for a refund. RSBCO’s legal team stated that the IRS had already lost its case in the first administrative claim and had failed to respond favorably to the company’s second claim. The company’s petition further noted that no harm had been caused by the errors, as the late returns were ultimately corrected without any significant impact on the government or other parties.
The Supreme Court’s decision to decline RSBCO’s petition effectively upholds the Fifth Circuit’s ruling, leaving the company with limited options for challenging the penalties. RSBCO’s attorneys argued that the case raised important issues about the application of tax laws and the treatment of mental health conditions in the workplace. The company expressed frustration with the IRS’s handling of the matter, noting that it had been forced to pay the penalties despite the lack of harm caused by the filing delays.
