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Tuesday, August 7, 2018

Ninth Circuit Withdraws Altera Opinions (8/7/18; 8/13/18)

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The Ninth Circuit has withdrawn its opinions in Altera Corp. et al. v. Commissioner , ___ F.3d ___, 2018 WL 3542989, 2018 U.S. App. LEXIS 2...
Thursday, August 2, 2018

SSRN Posting of Article on IRS Guidance -- Rulemaking and Deference (8/2/18)

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SSRN has posted for review and download my article on IRS Guidance.  titled IRS Guidance – Rulemaking and Deference to IRS Statutory Interpr...
Sunday, July 29, 2018

Ninth Circuit Rejects Midco Transaction Twice Blessed by Tax Court (7/29/18)

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In  Slone v. Commissioner , ___ F.3d ___, 2018 U.S. App. LEXIS 20602 (9th Cir. 2018),  here , the Ninth Circuit rejected the Midco variant. ...
Saturday, July 28, 2018

D.C. Circuit Reverses the Tax Court on Chevron Application (7/28/18)

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This week was not a good week for the Tax Court in the Courts of Appeals.  I have not attempted a complete survey of all Tax Court appeals i...

District Court Holds that Santander's Arguments to Avoid Penalty for Bullshit Tax Shelter (No Substance) Lack Substance (7/24/18)

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Here is an entry that I posted a few days ago on my Federal Tax Crimes Blog.  It is equally interesting to Federal Tax Procedure enthusiasts...
Wednesday, July 25, 2018

Developments - Federal Tax Procedure Book 2018 Editions and Altera (7/25/18; 7/27/18)

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The 2018 editions of the Tax Procedure Book (Student Edition and Practitioner Edition) are available for download on SSRN as of 7/17/18.  Th...
Saturday, April 21, 2018

Whistleblower Matters - Update (4/21/18)

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I have made updates to the working draft of the Federal Tax Procedure book based, in part, on a recent posting on the Procedurally Taxing Bl...
Saturday, February 24, 2018

Congress Amends Tax Whistleblower Section, § 7623, to Clarify Broad Reading of the Award Base (2/24/18)

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Earlier this month, Congress amended the mandatory minimum tax Whistleblower award program to make clear that proceeds for purposes of the a...
Friday, February 2, 2018

Good History Lesson on the Interface of Civil Procedure and Tax Refund Suits (2/2/18)

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In United States v. Stein , 2018 U.S. App. LEXIS 2392 (11th Cir. 2018) (en banc), here , the Eleventh Circuit unanimously held that "a...
Monday, November 27, 2017

Distinguishing the Internal Revenue Code from Title 26 (11/27/17)

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In my working draft for the 2018 edition of my Federal Tax Procedure book (scheduled for publication in August 2018), I have recently revise...