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Sunday, February 26, 2017

Interpretive and Legislative Regulations and the Relationship to Chevron (2/26/17)

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I have been struggling with the APA distinction between legislative and interpretive regulations and how that distinction might be impacted ...

Tax Procedure Book Errata - FBAR Filing Date (2/26/17)

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Book Outline Section Nature of Update Location for current editions Ch. 19.  Foreign Bank Account Reports (FBARs) And Related. I...
Saturday, February 11, 2017

Major Attorneys Fee Award for BASR Partnership Prevailing on the Allen Issue in Federal Circuit (2/11/17)

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In  BASR Partnership v. United States , [citation coming later] (2017),  here , the  Court of Federal Claims held that the partnership in a ...

Tax Procedure Book Errata - Notice of Deficiency Determination (2/11/17)

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    Book Outline Section Nature of Update Location for current editions Ch. 11 Notice of Deficiency ...
Thursday, February 9, 2017

Tax Procedure Book Errata - Correct Status of the Tax Court (1/2/17)

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Book Outline Section Nature of Update Location for current editions Ch. 2 III.B.2. Article I Courts...

Tax Procedure Book Errata - Corporation Income Tax Return Filing Date (1/2/17)

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Book Outline Section Nature of Update Location for current editions Ch. 5 ¶ 4.A., Time for Filing Returns - General State C Cor...
Monday, January 16, 2017

Statistics from the 2016 Whistleblower Office Report (1/16/17)

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The IRS Whistleblower Program Fiscal Year 2016 Annual Report to Congress,  here , reports the following statistics: Table 1: Amounts Co...

Tax Procedure Book Errata - Nonexistent or Phantom Regulations (1/2/17)

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Book Outline Section Nature of Update Location for current editions Ch. 2 II. Executive Branch.   B. IRS.  ...

The Tax Court Jurisdictional Brouhaha that Should Never Have Been - Malpractice Alert (1/16/2017)

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For many years through 2015, I taught Tax Procedure at the University of Houston Law School.  Some professors teach the subject at a more th...
Tuesday, January 3, 2017

SD NY District Court Rejects Partial Payment § 6707 Penalty Refund Suit (1/2/17)

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This is a reposting of the same entry on my Federal Tax Crimes Blog. In  Larson v. United States , 2016 U.S. Dist. LEXIS 179314 (SD NY 201...