Federal Tax Procedure Book 2024 Editions Updates (7/26/24; 3/29/25)

Federal Tax Procedure 2024 Cumulative Updates with Links

(Click on the Links to Go to Blog Entry with Update)

This page is to post significant changes to the 2024 editions as I revise the working draft for the 2025 editions that I published on SSRN in July or August 2025.   I make hundreds of changes during the year, but post here only the significant changes.  Each time I add an entry for significant changes, I change the date in the title of this page presented in parenthesis. For each of the significant changes that warrant a blog entry, I collect the update blogs in a search on labels titled "FTPB 2024 Updates," here.

Keep in mind that, since the updates are from the 2025 working draft which has a lot of changes from the 2024 editions, the page numbers will not be the same as in the 2024 editions and any links to other parts of the book will not be the same as in the 2024 editions.

  

Ch. 1. Purpose and Scope.

 

Ch. 2. Structure of the Federal Revenue Function.

 

Date	Outline	Prac. Ed.	Stud. Ed.	Brief Description of Change	Link to Revisions
9/24/24	Ch. 2 II.B.5.f.	87-93	60-64	Made substantial revisions to the discussion of Demise of Deference (readers should keep in mind that there will likely be future revisions as well). I do not show the changes in redline because there were so many that the redlines were more confusing than helpful.	Here

 

Ch. 3. Returns and Payments.

 

Ch. 4. Statutes of Limitations.

Date	Outline	Prac. Ed.	Stud. Ed.	Brief Description of Change	Link to Revisions
8/6/24	Ch. 04 ¶V.B.2.	226-230	157-161	Changes inspired by Libitzky v. United States, 110 F.4th 1166 (9th Cir. 2024)	Blog Here; Revisions to FTPBook, Here.

 

Ch. 5. Interest.

 

Ch. 6. Penalties.

Date	Outline	Prac. Ed.	Stud. Ed.	Brief Description of Change	Link to Revisions
3/29/25	Ch. 06 ¶ II.D.7.	317	221	Corrected to state that Bronston-type Literal Truth Defense for Perjury applies to False Statements under § 1001(a)(2)	Here
8/7/24	Ch. 06 ¶ II.B.	305	211-212	Expand introductory paragraph on nature of the Sentencing Guidelines	Here
9/24/24	Ch. 6, II.G.1.b.(2)	323-325	225-226	Expanded and corrected the discussion of the Formal VDP (“Noisy Disclosure”).	Here

 

Ch. 7. The IRS Compliance Function (Examination).

 

Ch. 8. Appeals.

 

Ch. 9.  Notice of Deficiency.

 

Ch. 10.  Litigation.

 

Ch. 11. Assessment Procedures.

 

Ch. 12. Collection Procedures.

 

Ch. 13. Overpayments.

 

Ch. 14. Miscellaneous.

 

Date	Outline	Prac. Ed.	Stud. Ed.	Brief Description of Change	Link to Revisions
10/13/24	Ch. 14.VIII.B.3.a.	876	591	Added the discussion (not verbatim) in Treasury Promulgates Syndicated Easement Listed Transaction Regulations (Federal Tax Procedure Blog 10/13/24), here.	See the blog entry

 

Ch. 15. Evidentiary Privileges in Tax Controversy Practice.

 

Ch. 16. Partnerships and S Corporations.

 

Ch. 17. Foreign Bank Account Issues (FBARs And Related).

 

Ch. 18a Corporate Transparency Act and Related Reporting

 

Ch. 18. Whistleblower Rewards.

 

Ch. 19. Ethics, Malpractice and Tax Procedure.

 

Ch. 20. Discovering What the IRS Knows–FOIA, Privacy Act, Etc.

 

Ch. 21. Confidentiality and Disclosure of Return Information

 

APPENDIX - RESOURCES