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Showing posts with label UH TPC 2013. Show all posts
Showing posts with label UH TPC 2013. Show all posts
Wednesday, December 4, 2013

More on the Supreme Court's Opinion in Woods on TEFRA and the 40% Basis Overstatement Penalty (12/4/13)

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I offer more detailed comments on United States v. Woods , ___ U.S. ___ (2013), here .  This blog entry is primarily for students. 1.  The...
Tuesday, December 3, 2013

Supreme Court Applies 40% Penalty to Bullshit Basis Enhancement Shelters (12/3/13)

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In  United States v. Woods , ___ U.S. ___ , 134 S. Ct. 557 (12/3/13),  here , the Court rejected procedural arguments and applied the speci...
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...
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...
Thursday, October 3, 2013

Court of Federal Claims Holds that Unlimited Civil Statute of Limitations Requires Taxpayer's Fraud (10/3/13)

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In BASR Partnership et al. v. United States , 113 Fed. Cl. 181 (2013), here , the Court of Federal Claims (Judge Susan G. Braden), in a part...
Saturday, September 14, 2013

Good Review Case on Claims for Refund and Variance for Tax Procedure Students (9/14/13)

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In Cencast Services, L.P. v. United States , 729 F.3d 1352 (Fed. Cir. 2013), here , the Federal Circuit (Judge Dyk) held that  1.  "...
Tuesday, September 10, 2013

Appeals Judicial Approach and Culture Project (AJAC) (9/10/13)

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Stephen Olsen blogs on the Procedurally Taxing blog on IRS's appeals new initiative / approach, called Appeals Judicial Approach and Cul...