The government, represented by Elizabeth Prelogar from the U.S. Solicitor General’s Office, did not respond to RSBCO’s petition, opting instead to waive its right to comment. RSBCO’s legal team, led by Russell Alan Woodward Jr. of the Law Offices of Russell Alan Woodward Jr. LLC, has not indicated whether it plans to pursue further legal action.
The IRS penalties had originally been imposed due to the employee’s 42-day delay in correcting the errors in the returns. The agency had initially flagged the issues and required corrections, but the employee’s mental health struggles had prevented an immediate response. In the petition, RSBCO emphasized that the company had no prior filing issues and that the employee’s personal difficulties were not known at the time.
RSBCO’s legal team also contended that the IRS’s actions were unfair and that the penalties were excessive. They argued that the company had taken steps to address the issue promptly after the filing mistakes were identified. Despite the challenges, RSBCO’s legal team expressed confidence that the company had complied with all necessary procedures, although it faced an uphill battle in the appellate process.
