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Thursday, September 20, 2012

Erroneous Refund Suit is Timely Filed (9/20/12)

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In United States v. Davenport , 2012 U.S. Dist. LEXIS 131468 (ND TX 2012), here, the Court held in an erroneous refund suit that the Governm...

IRS Proposes New Practitioner Rules for Opinions and Advice (9/20/12)

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The IRS has proposed new regulations for Circular 230, 31 CFR Part 10, regarding tax practitioner opinions and advice.  See REG-138367-00, 7...
Wednesday, September 19, 2012

The Role of the DOJ Tax Division (9/18/12)

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I have just published a blog entry on the Tax Division.  See  The Role of the DOJ Tax Division in Criminal Tax Enforcement (Federal Tax Cri...
Tuesday, September 18, 2012

DOJ Tax Authority to Settle Tax Cases in Joint Committee Cases (9/18/12)

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In United States v. United States District Court for the Northern Mariana Islands , ___ F.3d ___, 2012 U.S. App. LEXIS 19134 (9th Cir. 2012)...

The Scalia-Posner Spat Over Statutory Interpretation (9/18/12)

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The Scalia-Posner spat is ratcheting up, with Justice Scalia allegedly accusing Judge Posner of the big lie -- Posner's assertion that S...
Saturday, September 15, 2012

Whistleblowers, Carried Interests, Fee Waivers and Swiss Banks (9/15/12)

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I previously blogged as to the claim that Revenue Procedures was a legal basis for claiming capital gains for carried interests and the more...

Adequacy of IRS Notices & Variance in Refund Claims (9/15/12)

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In Bush v. United States , 2012 U.S. Claims LEXIS 1083 (2012), here , the Court of Federal Claims held in a tax refund suit that a computati...

The Danielson Rule: Holding a Taxpayer to his Bargain (9/15/12)

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In Hartman v. United States , 694 F. 3d 96 (Fed. Cir. 2012), here , the Federal Circuit applied the constructive receipt rule to tax a servi...
Friday, September 14, 2012

Mootness and Tax Court Proceedings (9/14/12)

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OK, I know the reaction of most readers for this blog is going to be "So What."  That is probably a good reaction, but I persist i...

If It's A Tax, What About the Origination Clause? (9/14/12)

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One of our first topics in my Federal Tax Procedure class is the roles of the various players -- Congress, the Executive Branch and the Cour...