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Wednesday, September 25, 2013

Taxpayer Judicially Estopped from Refund For Taxes Admitted in Plea Agreement (9/25/13)

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In  Mirando v. United States , 2013 U.S. Dist. LEXIS 135659 (ND OH 2013), the taxpayer pled guilty to conspiracy and tax evasion.  The plea ...
Tuesday, September 24, 2013

Government Refusal to Grant Immunity Shifts Burden of Proof to IRS in Tax Court Case (9/24/13)

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In an Order dated 9/17/13 in  AD Investment 2000 Fund LLC v. Commissioner  (Dkt Nos. Docket No. 9177-08, 9178-08),  here , the Tax Court (Ju...
Saturday, September 21, 2013

IRS New Revenue Procedure for Innocent Spouse Equitable Relief (9/21/13)

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The IRS has released Rev. Proc. 2013-34, 2013-42 IRB 1, here , which " provides guidance for a taxpayer seeking equitable relief from...

Schedule UTP and Penalties (9/21/13)

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Lee Sheppard has an interesting article on privileges addressing issues in Wells Fargo & Company v. United States , 2013 U.S. Dist. LEXI...

Yet Another Bullshit Tax Shelter Goes Down; BB&T's Streak on Bullshit Tax Shelters Continues (9/21/13)

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In  Salem Financial, Inc. v. United States , 112 Fed. Cl. 543, 2013 U.S. Claims LEXIS 1372 (9/20/13),  here , the court (Judge Wheeler) rej...
Wednesday, September 18, 2013

TIGTA Report Recommends Steps to Minimize Risk of Outside Influence in Letter Rulings (9/18/13)

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Here is the summary of the TIGTA report with links to the report CHIEF COUNSEL SHOULD TAKE STEPS TO MINIMIZE THE RISK OF OUTSIDE INFLUENCE...
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...
Friday, September 6, 2013

Tax Court Blesses a Taxpayer Designation of Payment (9/6/13)

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I had intended to do a blog on the Tax Court decision in Dixon v. Commissioner , 141 T.C.; No. 3 (2013), here .  The background is that a t...
Wednesday, September 4, 2013

Tax Controversy is a Hot Growth Area of the Practice (9/4/13)

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From the estimable Tax Prof Blog - Tax Controversy and Litigation: One of the 12 Hot Practice Areas for 2020 and Beyond (Tax Prof Blog 9/4...