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Showing posts with label Flora Full Payment Rule. Show all posts
Showing posts with label Flora Full Payment Rule. Show all posts
Sunday, September 11, 2016

Tax Procedure Book Errata - Special Flora Mitigation Procedures for Certain Assessable Penalties (9/11/16)

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I will revise the book to insert the following with respect to certain assessable penalties -- the return preparer penalties under § 6694 an...
Saturday, March 12, 2016

District Court holds the § 6707 Tax Shelter Reporting penalty Not Divisible (3/12/16)

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I previously reported on a case in the Court of Federal Claims, Diversified Group Inc. v. United States , 123 Fed. Cl. 442, 2015 U.S. Claims...
Thursday, September 17, 2015

Flora Full Payment Rule and the Rough Edges (9/17/15)

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In the class we discuss the rule -- called the Flora rule -- that, in order to maintain a tax refund suit, the taxpayer generally must full...
Wednesday, January 29, 2014

Revised Opinion in TFRP Case Involving Flora Full Payment Requirement (1/29/14; 2/21/14)

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I recently blogged on the Court of Federal Claims'  Kaplan case, Kaplan v. United States , 2013 U.S. Claims LEXIS 1530 (10/9/13) applic...
Saturday, January 18, 2014

Court of Federal Claims Transfers to Tax Court Case Failing Flora Full Payment Rule (1/18/14)

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Caution: the decision discussion immediately below has been reversed; the revised decision is discussed toward the end of this blog. In C...
Monday, November 11, 2013

Fourth Circuit Affirmance of Summary Judgment in TFRP case (11/11/13)

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In Johnson v. United States , ___ F.3d ___, 2013 U.S. App. LEXIS 22444 (4th Cir. 2013), here , the Fourth Circuit affirmed summary judgment ...
Friday, October 11, 2013

Litigating Trust Fund Recovery Penalties -- the Flora Rule, Divisible Taxes and Unfairness (10/11/13)

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UPDATE, most of the discussion below is still good, but Judge Wheeler of the Court of Federal Claims issued a new opinion going the opposite...
Friday, January 18, 2013

TFRP Refund Suits - How Much Must be Paid (1/18/13)

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I write today on the Government's position -- pressed only once that I am aware of and not accepted or specifically rejected by any cour...