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Thursday, April 30, 2020

Are Discussions with Lawyer Colleagues Waivers of the Work Product Privilege? (4/30/20)

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Today, I discuss a facet of the work-product doctrine, often called the work product privilege.  I address waiver for opinion work product i...
Monday, April 27, 2020

8th Circuit Rejects Wells Fargo Bullshit Tax Shelter (4/27/20)

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In Wells Fargo & Company v. United States , ___ F.3d ___ (8th Cir. 2020), here , the Eight Circuit rejected the taxpayer’s claim of enti...
Sunday, April 26, 2020

Fifth Circuit Rejects Attorney-Client Identity Privilege for Law Firm Documents (4/26/20)

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In Taylor Lohmeyer Law Firm P.L.L.C. v. United States , ___ F.3d ___ (5th Cir. 4/24/20), here, the Court of Appeals affirmed the district co...
Thursday, April 16, 2020

Tax Court Power to Reform Contract Involving Party Not Before the Court (4/16/20)

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In Hoffman Properties II v. Commissioner , 956 F.3d 832  (6th Cir. 4/14/20), CA6  here  and GS here , the Court affirmed the Tax Court’s den...
Saturday, April 4, 2020

Chevron and Shakespeare (4/4/20)

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On my self-isolating walk today in the Charlottesville neighborhood (beautiful), I listened to a podcast interview of Emma Smith, the author...
Thursday, April 2, 2020

Section 7805(a) - Legislative or Interpretive and Problem of Retroactivity (4/2/20; 4/24/20)

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In my article, The Report of the Death of the Interpretive Regulation Is an Exaggeration (SSRN last revised 2/28/20, here ), I argued that ...
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...