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Wednesday, October 31, 2012

Creation of the Joint Committee on Taxation (10/31/12)

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For those who like tax law and history, George Yin, Professor at UVA Law and formerly Chief of Staff of the Joint Committee on Taxation, has...
Tuesday, October 30, 2012

Review of CDP Appeals Procedures (10/30/12)

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In Tucker v. Commissioner , 676 F.3d 1120 (D.C. Cir. 2012), here , the D.C. Circuit rejected the taxpayer's Appointments Clause argument...
Saturday, October 27, 2012

IRS Issues new Bankruptcy Tax Guide, Publ 908 (10/27/12)

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The IRS has issued a new version of the Bankruptcy Tax Guide , Publication 908 (October 2012).  The pdf version is here and the html versio...
Saturday, October 20, 2012

Relationship Between Tax Court and Refund Fora - Burden to Prove Fraud (10/20/12)

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In my Federal Tax Procedure course (and I presume similar courses taught by others), we cover the principal fora to litigate tax disputes.  ...
Friday, October 19, 2012

Trust Fund Recovery Penalty and Judge Posner

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Judge Posner has been much in the news recently.  Last night in the UH Tax Procedure Class we covered the Trust Fund Recovery Penalty (...
Wednesday, October 17, 2012

First Time Abatement for FTF and FTP Penalties (10/17/12)

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TIGTA issued a report on the First Time Abate Penalty waiver of failure to file (FTF) and failure to pay penalties under Section 6651(a)(1) ...

Incentives for Corporate Tax Planning and Avoidance (10/17/12)

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John R. Graham, Michelle Hanlon, Terry Shevlin and Nemit Shroff, Incentives for Tax Planning and Avoidance: Evidence from the Field (SSRN 9...
Tuesday, October 9, 2012

Render Unto Caesar -- Another Intersection of Alleged Religion and Tax (10/9/12)

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In  Hovind v. Commissioner , T.C. Memo. 2012-281,  here , the Tax Court decided decided that the taxpayer had "had unreported Schedule ...
Wednesday, October 3, 2012

Trust Fund Recovery Penalty (TFRP) Procedures (10/3/12)

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In the UH Tax Procedure Class we will spend a good bit of time on the Trust Fund Recovery Penalty ("TFRP"), Section 6672, here.  T...
Monday, October 1, 2012

Mr. Romney's Returns Not Claiming All of His Charitable Deductions (10/1/12)

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I normally did not stoop to politics (at least overtly) in this blog.  (Outside this blog, I do have opinions and sometimes express them.)  ...