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Sunday, August 18, 2019

Amazon Wins Transfer Pricing Dispute on Regulations Interpretation (8/18/19)

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In  Amazon.com, Inc. v. Commissioner , ___ F.3d ___ (9th Cir. 2019),  here , a transfer pricing case, the Court held that, under the applica...
Wednesday, August 14, 2019

Procedurally Taxing Offering and Discussion of IRS Graphic on Tax Litigation (8/14/19)

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Students and Practitioners reading this blog (and the Federal Tax Procedure Book) will know that I recommend the Procedurally Taxing Blog, h...
Monday, August 12, 2019

2019 Federal Tax Procedure Book Editions Available (8/12/19)

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The 2019 editions of the Tax Procedure Book (Student Edition and Practitioner Edition) are available for download on SSRN as of 8/12/18.  Th...
Friday, August 9, 2019

IRS Release on Passport Denial and Revocation for Seriously Delinquent Tax Debt (8/9/19)

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The IRS released IR-2019-141 (8/8/19), here , titled: "Individuals with significant tax debt should act promptly to avoid revocation of...
Thursday, August 8, 2019

District Court Invalidates Interpretive Regulation at Chevron Step One (8/8/19; 3/11/19)

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In Mayo Clinic v. United States (D. Minn. No. 16-cv-03113 Opinion and Order dated 8/6/19), here , the Court invalidated an IRS "interp...
Tuesday, August 6, 2019

Pre-Enforcement Litigation of IRS Guidance (8/6/19)

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I just finished today my 2019 editions (Practitioner and Student) of my Federal Tax Procedure Book.  I have submitted those editions to SSRN...
Saturday, August 3, 2019

Restitution Based Assessment--Some Issues of Interest (8/3/19; 8/7/19)

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Readers of this blog will likely be interested in a recent post on Procedurally Taxing Blog:  Keith Fogg,  Interest and Penalties on Restitu...

Court Invalidates IRS Attempt by Rev Proc to Change Legislative Regulation (8/5/19; 12/10/20)

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In Bullock v. IRS , 401 F. Supp. 3d 1144 (D. Mont. 2019), here , the court held that the IRS's use of a Revenue Procedure to revoke a re...
Thursday, July 11, 2019

More on Litigation and IRS Raising Civil Fraud New Matter (7/11/19)

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My last post involved the IRS raising the civil fraud penalty as new matter by amended answer and prevailing. IRS Raises Fraud In Tax Court ...
Wednesday, July 10, 2019

Tax Court Sustains § 6701 Penalty Against Preparer (7/10/19)

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In Kapp v. Commissioner , T.C. Memo. 2019-84, here , the Tax Court sustained § 6701 penalties of $3,218,000 (after certain IRS concessions p...