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Sunday, November 24, 2019

Court Denies Summary Judgment to Party with Burden of Persuasion Because that Party's Testimony Evidence May Not Be Believed (11/24/19)

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In Martinelli v.Commissioner , (T.C. Dkt No. 4122-18 Designated Order 9/20/19), here , the IRS issued a deficiency against Martinelli and s...
Friday, November 22, 2019

RICO Claim Dismissed Against Bullshit Tax Shelter Promoters (11/22/19)

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Note: This is posting to the Tax Procedure Blog of an earlier posting on my Federal Tax Crimes Blog, that I decided to copy and post here be...
Monday, November 18, 2019

On Judge Richard Posner (11/18/19)

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I recently posted the following entry.  The Notice of Deficiency (Federal Tax Procedure Blog 11/8/19), here .  In that post, I had the foll...
Wednesday, November 13, 2019

Sixth Circuit Holds that Courts Cannot Enjoin IRS From Receiving or Using Alleged Confidential Info from Former Attorney (11/13/19)

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Note:  I posted this earlier on the Federal Tax Crimes Blog here , but since it overlaps with Federal Tax Procedure, I post it here. In  G...
Tuesday, November 12, 2019

Altera Corp. Petition for Rehearing Denied (11/12/19)

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I have written before about the cause célèbre that is the Altera case.  Altera Corp. v. Commissioner , 145 T.C. 91 (2015), here , rev'd ...
Friday, November 8, 2019

The Notice of Deficiency (11/8/19)

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Tax Procedure fans should follow Bryan Camp's weekly offerings on the Tax Prof Blog, here (the link is to the cover page for the blog)....
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...