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Wednesday, February 20, 2019

Federal Tax Procedure Update on Tax Crimes (2/20/19)

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Today, I completed revisions to the Tax Crimes section of my Federal Tax Procedure Book so that I could circulate to Jim Malone's Tax Pr...
Thursday, February 14, 2019

Taxpayer Advocate Annual Report with Graphics on the Tax Procedure Processes (2/14/19)

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The Taxpayer Advocate has issued the Annual Report to Congress for 2018, here .  There is a lot in the report that I will blog on here (or i...
Monday, January 21, 2019

More on Fact Finding Tools and Statutory Interpretation through Chevron Deference (1/21/19; 1/25/19)

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The Chevron Framework that is so ubiquitous in administrative law now (see e.g., Law Finding (The Chevron Framework) and Fact Finding in Tr...
Sunday, January 20, 2019

Yet Another Confluence of Legal Interpretation and Fact Finding--Legislative History (1/20/19)

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In statutory interpretation, textualists and their fellow travelers often eschew (or claim to eschew) legislative history as a reliable guid...
Saturday, January 19, 2019

Another Confluence of Legal Interpretation and Fact Finding (1/19/19)

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Earlier today I posted on a confluence of legal interpretation and fact finding:  Law Finding (The Chevron Framework) and Fact Finding in Tr...

Law Finding (The Chevron Framework) and Fact Finding in Trials (1/19/19)

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As a trial lawyer and an observer of statutory interpretation, I have observed some parallel in statutory interpretation (a law finding proc...
Saturday, January 12, 2019

Treasury Regulations and the APA Categories of Legislative and Interpretive Regulations (1/12/19; 1/19/19)

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NOTE: THIS WAS SUBSTANTIALLY REVISED AND EXPANDED ON 1/13/19) Note that Bob Probasco, Senior Lecturer and Director of the Low Income Tax C...
Monday, January 7, 2019

Sex and Tax (1/7/19)

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I have just posted this  Sex and Tax (Including the Tax Division) in the Movies (DOJ Tax Division Alumni Blog 1/7/18), here .  This is abou...
Wednesday, January 2, 2019

Centralized Partnership Audit Regime (CPAR) Update -- Looking for Reviewer Volunteers (1/2/19)

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I am in the process of finishing up a substantial revision of my discussion of the relatively new Centralized Partnership Audit Regime (...
Sunday, December 23, 2018

New Third Circuit Decision on Suits to Recover FBAR Penalties and on Expanded Meaning of Willfulness (11/23/18)

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Tax Procedure Enthusiasts might be interested in this posting on my Federal Tax Crimes Blog:  Bedrosian on Appeal; Interesting and Potential...