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Monday, September 28, 2015

Good Review of Points Previously Covered in Class (9/28/15)

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Lua v. United States , 2015 U.S. Claims LEXIS 1235 (9/25/15), here , offers a good review of concepts we have studied in this case. In Lua...
Saturday, September 26, 2015

Writing Tips from a Master (9/26/15)

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This is not about tax procedure.  It is about writing and persuading.  The goal of learning tax procedure is to persuade in a tax setting.  ...
Friday, September 25, 2015

Are Appeals Officers Equipped and Trained to Assess Accurately the Litigating Hazards of a Case? (9/25/15)

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Appeals' standard for settlement is to reflect the litigating hazards of the case.  See IRM 8.6.4.1  (10-26-2007), Fair and Impartial Se...
Thursday, September 24, 2015

Revision to Texts on Tax Shelters and Case Assignment (9/24/15)

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I have assigned in Unit/Class 10 the following case (trial and appellate level opinions):   Compaq Computer Corp. v. Commissioner , 113 T.C....
Thursday, September 17, 2015

Flora Full Payment Rule and the Rough Edges (9/17/15)

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In the class we discuss the rule -- called the Flora rule -- that, in order to maintain a tax refund suit, the taxpayer generally must full...
Saturday, September 12, 2015

IRS Terminates Appeals Arbitration (9/12/15)

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The IRS has terminated Appeals arbitration.  Rev. Proc. 2015-44, 2015-38 IRB 1, here I have revised the text of the pdf text books.  In th...
Friday, September 11, 2015

Payment of "Tax" After the Assessment Limitations Period Expires - Refunds (9/11/15)

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Apropos to our discussions in class of the statute of limitations on assessment, in ECC 201536020 (9/4/15), here , the IRS attorney addresse...
Tuesday, August 18, 2015

What is the Date of Filing for Returns Solicited by and Delivered to an Agent (8/18/15)

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I posted a blog on my Federal Tax Crimes Blog that may have some discussion that Federal Tax Procedure enthusiasts may find interesting.  Th...
Tuesday, August 11, 2015

Overstatement of Basis Included in Gross Income Omission for 6-Year Statute of Limitations (8/11/15)

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In United States v. Home Concrete , ___ U.S. ___, 132 S.Ct. 1836 (2012), here , the Supreme Court held that an overstatement of basis that h...
Monday, August 10, 2015

Prescient History from the Records of the Constitutional Convention on the Origination Clause (8/10/15)

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Note:  I have appended to the end of this blog the legal background for the brouhaha, drawn principally from the bipartisan Senate Finance ...