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Wednesday, October 23, 2013

Another Bullshit Tax Shelter Bites the Dust (10/23/13)

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Here is yet another of the genre.   UnionBanCal Corporation v. United States  , 113 Fed. Cl. 117 (10/23/13),  here . The first tip-off as...
Monday, October 21, 2013

Tax Court Announcement on Effect of Government Shutdown (10/21/13)

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The United States Tax Court, here , has issued an announcement regarding the resumption of Tax Court operations after the Government Shutdo...
Saturday, October 19, 2013

Contesting Liability -- CDP, Audit Reconsideration and OICs for Doubt as to Liability (10/19/13)

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Last week in my Tax Procedure Class, we covered Collections generally.  Subsets of collections that were covered were (i) audit reconsidera...
Friday, October 18, 2013

A Not So Bullshit Tax Shelter -- Maybe; Its All in the Eye of the Beholder (10/18/13)

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Today's blog addresses yesterday's decision from a very good judge, George A. O'Toole, Jr. of USDC MA (Wikipedia here ).  The de...
Wednesday, October 16, 2013

Is the Tax Court Constitutional? (10/16/13)

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My fellow tax procedure bloggers over at the Procedurally Taxing Blog have posted this item.   Potential Storm Over Removal Power of Tax Cou...

On Qualified Amended Returns and Avoiding Amnesty Penalty Costs (10/16/13)

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I picked up today a recent post on the Tax Appellate Blog, Miller & Chevalier's offering to the world on things tax (at least the ap...
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 10, 2013

IRS Information on Operations During Government Shutdown (10/10/13)

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The IRS has a website advising of operations during the shutdown.  See IRS Operations  During The Lapse In Appropriations ,  here .  Here ar...
Friday, October 4, 2013

IRS Not Liable for Opening FBAR Investigation Based on Return Information Subject to Section 6103 (10/4/13)

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In  Hom v. United States , 2013 U.S. Dist. LEXIS 142818 (ND CA 9/30/13), the taxpayer brought suit for damages for alleged IRS violations of...
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...