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Showing posts with label Notice of Deficiency. Show all posts
Showing posts with label Notice of Deficiency. Show all posts
Monday, January 16, 2023

Further Commotion in Liberty Global Collection Suit Over Whether a Notice of Deficiency Is Required Before Collection Suit (1/16/23; 1/19/23)

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Updated 1/19/23 with Court docket entry stating that the claim Liberty Global wanted to assert should not be filed.  See Comment #2 below. I...
Thursday, March 18, 2021

More on Delegations of Authority, Notices of Deficiency and Consents to Extend (3/18/21)

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Yesterday, I posted on a case, Harriss v. Commissioner , T.C. Memo. 2021-31, that led me into a discussion of delegated authority to make de...
Friday, November 8, 2019

The Notice of Deficiency (11/8/19)

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Tax Procedure fans should follow Bryan Camp's weekly offerings on the Tax Prof Blog, here (the link is to the cover page for the blog)....
Tuesday, October 16, 2018

Attorney Fraud Resulting in Tax Court Decision; Can It Be Corrected? How? (10/16/18; 10/17/18)

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This article caught my attention today:  Bruce Vielmetti,  Former Foley & Lardner partner suspended for falsifying documents in IRS ...
Monday, September 28, 2015

Good Review of Points Previously Covered in Class (9/28/15)

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Lua v. United States , 2015 U.S. Claims LEXIS 1235 (9/25/15), here , offers a good review of concepts we have studied in this case. In Lua...
Saturday, March 7, 2015

Seventh Circuit Opinion on Role of Notice of Deficiency and Last Known Address Requirement (3/7/15)

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In Gyorgy v. Commissioner , ___ F.3d ___, 2015 U.S. App. LEXIS 3100 (7th Cir. Feb. 27, 2015), here , the Court addressed certain key aspects...
Friday, November 29, 2013

Principal Life -- A Masterpiece of Tax Procedure (11/29/13)

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In my last Tax Procedure Class, we spent most of the class discussing Principal Life Ins. Co. v. United States , 95 Fed. Cl. 786 (Fed. Cl. 2...
Saturday, August 17, 2013

Practitioner Warns of IRS Letters and Notices to Not Ignore (8/17/13)

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Edward M. Robbins, Jr., a prominent tax litigator (see bio page here ), has posted a good series of articles on six IRS Letters and Notices ...