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Thursday, May 15, 2014

Another Bullshit Shelter Bites the Dust Even with Variations (5/15/14)

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I write today on the defeat of another bullshit tax shelter of the Son-of-Boss ("SOB") variety.   The Markell Company, Inc. v. Com...
Tuesday, May 6, 2014

The Chevron Two-Step (5/6/14)

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Tax Procedure enthusiasts know -- or should know -- that  Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. , 467 U.S. 837 (19...
Sunday, May 4, 2014

Role and Culpability of Taxpayers Participating in Bullshit Tax Shelters (4/4/14)

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I write today to collect and update some thoughts I have expressed before on this blog.  The background is the bullshit tax shelters on whic...
Friday, May 2, 2014

Discovery from IRS Files and Employees About Fair Notice of Liability and Treatment of Other Taxpayers (5/2/14)

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In NetJets Large Aircraft, Inc. v. United States , 2014 U.S. Dist. LEXIS 58677 (SD OH 2014), here , Magistrate Judge Terence P. Kemp, here ,...
Thursday, May 1, 2014

What Does Shall Mean? Herein of Slippery Mandatory Language and Summons Enforcement (5/1/14)

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In  Jewell v. United States , 2014 U.S. App. LEXIS 7899 (10th Cir. 2014),  here , the Court held that shall means shall.  So stated, not a s...
Tuesday, April 22, 2014

Crossing the Line in Tax Planning (4/22/14)

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I report today on a civil case that shows how a civil dispute can involve a situation that perhaps should have been a criminal case.  In Mor...
Thursday, April 17, 2014

GE Ducks Any Penalty for Its Bullshit Tax Shelter -- For Now (4/17/14)

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I have previously written on GE's bullshit tax shelter twice blessed by the district court and twice swatted down by the Court of Appeal...
Thursday, April 3, 2014

The Mitigation Provisions of the Code - An Example of How They Work to Open an Otherwise Closed Year (4/3/14)

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All taxpayers facing a tax liability hope that the IRS will fail to assess within the applicable period of limitations.  For example, the IR...

The IRS Levy Power (4/4/14)

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I have recently had email discussions with Leslie Book and Keith Fogg, authors of the Procedurally Taxing Blog, here , regarding some aspec...
Tuesday, February 11, 2014

Writ Ne Exeat Republica to Restrain from Foreign Travel as Tax Collection Tool (2/11/14)

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Readers might like to read two good discussions of the writ  ne exeat republica , which courts may issue in tax cases under 7402(a),  here ...