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Monday, March 30, 2020

Bullshit Shelter Taxpayers Continuing FOIA Litigation to Identify Informants Turning Them In to IRS (3/30/20)

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FOIA requests and litigation have not been featured prominently on this blog.  For this entry, FOIA litigation is front and center, but inte...
Sunday, March 22, 2020

District Court Muddles an FBAR Willful Penalty Case (3/22/20; 3/24/20)

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I made a key revision on 3/24/20 at 4:00pm as indicated in red below to state with cites to the statute that the willful FBAR willful penalt...
Wednesday, March 18, 2020

Swiss Bank Account Records as Business Records for Hearsay Exception (3/18/20)

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In a designated order, Tax Court Judge Lauber rejected taxpayer objections to the introduction of records obtained by the IRS pursuant to th...
Saturday, March 14, 2020

Legislative Adjudicatory "Rulemaking?" (3/14/20; 3/16/20)

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I write today on a wrinkle that I recently discovered relating to an argument that I made in an article, The Report of the Death of the Inte...
Monday, March 2, 2020

Guedes Cert Denial on Bump Stock as Machinegun, Justice Gorsuch's Cryptic Statement and My Digression (3/2/20; 3/5/20)

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The Supreme Court this morning denied certiorari in Guedes v. Bureau of ATF , 920 F.3d 1, 7 (D.C. Cir. 2019), here , cert. den. 589 U.S. ___...
Monday, February 24, 2020

Baldwin Cert Denied with Justice Thomas' Rant on Chevron and My Rant on His Rant (2/24/20; 2/27/20)

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Today, the Supreme Court denied the taxpayer’s petition for certiorari in Baldwin v. United States, 921 F.3d 836, 840 (9th Cir. 2019), cert....
Wednesday, February 19, 2020

District Court Teaches Confusing Summary Judgment Lesson (2/19/20)

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In United States v. Feldman , 2020 U.S. Dist. LEXIS 24162 (E.D. Mich 2/12/20), CL here (and docket entries here ) in a collection suit, the...
Thursday, February 13, 2020

GAO Report on Virtual Currency Guidance (2/13/20)

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The Government Accountability Office (“GAO”) issued a report titled:  Virtual Currencies: Additional Information Reporting and Clarified Gui...
Wednesday, February 12, 2020

Altera Petition for Certiorari (2/12/20; 2/13/20)

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Readers of this blog will know that the Altera drama has been the topic of many of my thoughts. See Altera Corp. v. Commissioner , 145 T.C....
Monday, February 10, 2020

ICF Reg Map Available for Notice and Comment Regulation Process (2/10/20)

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Readers of the Federal Tax Procedure Blog will know that I have used some blog entries to discuss administrative law, the APA and the inters...