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Wednesday, October 30, 2019

Cert Petition Filed in Baldwin re Timely-Mailing, Timely Filing Regulations and Chevron (10/30/19)

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Some conservative/libertarians who claim loudly to fear the administrative state are now worked up over a tax case.  In Baldwin v. United S...
Saturday, October 26, 2019

Giants in Tax Law: Roger John Traynor (10/26/19; 8/26/23)

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I am spending more time than perhaps I should reading some old law review articles by giants in the tax law.  I will do a series of posts i...
Thursday, October 24, 2019

Some History on the Innocent Spouse Provisions (10/24/19)

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I thought I would point readers to Bryan Camp's recent post Bryan Camp, 100th Lesson From The Tax Court: The Role Of Innocence In § 6015...
Tuesday, October 22, 2019

FTPB Update 04 - District Court Litigation Types (10/22/19)

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I am doing the Updates differently, principally because I have learned how to do footnote links in the blog entry itself.  Accordingly, I ha...
Friday, October 18, 2019

The Mitigation Provisions of the Code Are Hard (10/18/19)

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In Whitesell v. Commissioner , T.C. Memo. 2019-126, here , the facts are somewhat complex but for present purposes are fairly presented in t...
Monday, October 14, 2019

Make Tax Procedure Great Again Caps for Sale (10/14/19; 6/2/22)

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I am offering for sale the "official" cap --  Make Tax Procedure Great Again (see image at right). I offer them for a per unit c...
Friday, October 11, 2019

On Statutory Interpretation - Textualism / Originalism (10/11/19; 10/16/19)

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Just this week, I was working on the issue of “original public meaning” to update my Federal Tax Procedure Book and earlier article that nee...
Wednesday, September 25, 2019

Chief Counsel Advice to IRS Attorneys on Treasury and IRS Policy Statement on Tax Regulatory Process (9/25/19)

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I have written before on this blog and in a recent article on the subject of the continuing viability of IRS interpretive regulations under ...

FTP2019 Update 03 - Minimum Payments and Voluntary Payments with OICs (9/25/19)

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I have posted Update 03, here , dealing with minimum and voluntary payments required with OICs.  A listing of updates (with links) through t...
Monday, September 23, 2019

Pfizer Suit for Overpayment Interest Transferred to CFC for Tucker Act Jurisdiction (9/12/19; 9/25/19)

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I write today on the recent decision in Pfizer, Inc. v. United States , 939 F.3d 173 (2d Cir. 2019), here .  Pfizer involves overpayment in...