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Friday, January 31, 2020

Legislative Rules And Chevron Deference An Oxymoron? (1/31/20; 2/10/20)

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Today, I address courts frequent statements about Chevron deference applying to legislative rules.  I was reading the decision in Renewable...
Tuesday, January 28, 2020

Updated Article on APA Interpretive Regulations (1/28/20)

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In June, I posted an a blog on article on the APA issue of the continued viability of the interpretive regulation.  Article on the Continue...
Thursday, January 23, 2020

Does the Period Go Inside or Outside the End Quote? A Tax Court and Supreme Court Comparison (1/23/20; 1/25/20)

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Added 4/9/20:  I have been advised that the Tax Court has a style manual that, paraphrased, says the rule is:  "periods go inside quote...

TRAC Report on Fewer Civil Tax Cases in District Courts (1/23/20)

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TRAC has this report:  Federal Civil Tax Suits Fall by Half Over Last Decade (TRAC 1/22/20), here .  Note that this report does not includ...

Tax Court Holds the TFRP is a Penalty Subject to § 6751(b) Supervisor Written Approval Requirement (1/23/20)

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Update 1/27/20 9:15am:  Bryan Camp offers an excellent discussion of Chadwick :  Bryan Camp, Lesson From The Tax Court: §6672 Trust Fund Rec...
Wednesday, January 22, 2020

Microsoft Summons Enforcement on Transfer Pricing "Planning" - Mixed on Privilege Claims (1/22/20)

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After publishing this blog entry, a new article was published about Microsoft's transfer pricing planning and the audit.  I discuss tha...
Tuesday, January 21, 2020

Presumption of Correctness and Burden of Proof (Persuasion) (1/21/20; 12/28/22)

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As revised 12/28/22. As revised on 12/28/22, the blog below is too long and has some diversions.  I try to be helpful to readers by the foll...
Thursday, January 16, 2020

Criminal Tax Evasion and Civil Fraud–If Found by the Trier, Can There be a Reasonable Cause/Good faith Defense (1/16/20; 1/17/20)

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I have blogged several times on my Federal Tax Crimes Blog about how the “good faith” defense is subsumed in the definition of willfulness f...
Saturday, January 11, 2020

FTP2019 Update 05 - § 6751(b)'s Requirement for Supervisor Written Approval for Penalties (1/11/20; 11/17/23)

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Yesterday, I posted this as a standalone blog entry, but decided to incorporate it into the FTPB Update series.  Accordingly, I changed the ...
Wednesday, December 25, 2019

Tax Perjury, § 7206(1) Is a Different Crime than Perjury, 18 USC § 1621 (12/25/19)

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The following is a copy of a post to my Federal Tax Crimes Blog: Yesterday, I was updating the working draft of my Federal Tax Procedure B...