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Thursday, January 28, 2021

Tax Court Opinion on Various Aspects of Collection Activity for RBAs and Coordination with DOJ (1/28/21)

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 In  Reynolds v. Commissioner , T.C. Memo. 2021-10, TC Dkt entry #20  here  * and TN  here , in a collection due process (“CDP”) case, the C...
Monday, January 18, 2021

Sunstein Articles Supporting Chevron Deference (1/18/21)

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Readers of this blog know that conservative and libertarian judges have noised since around 2000 that the Chevron “Framework” derived from ...
Saturday, January 16, 2021

Outstanding Article on Current State of IRS Voluntary Disclosure Practice (1/16/21)

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 This brief blog today is to alert readers to an outstanding article on the current state and some uncertainties and risks of the IRS Volunt...
Monday, January 11, 2021

Deloitte and Tax Analysts Open Tax Analysts Library to Public Without Subscription (1/11/21; 1/12/21)

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Last week, Deloitte posted this news release:  Deloitte and Tax Analysts Take Great Strides to Increase Tax Policy Transparency:  Profession...
Wednesday, January 6, 2021

Whistleblower FYE 2020 Report (1/6/21)

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 The IRS Whistleblower Office has released a report titled  Fiscal Year 2020 annual report ,  here .  The opening message from the Director ...
Wednesday, December 9, 2020

PDR on Remand to 4th Circuit with Further Confusion of the APA's Legislative / Interpretive Rule Distinction (12/9/20)

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In Carlton & Harris Chiropractic Inc. v. PDR Network, LLC , 2020 U.S. App. LEXIS 38073 (4th Cir. 2020), here , the Fourth Circuit punted...
Thursday, December 3, 2020

CIC Services Supreme Court Oral Argument (12/3/20)

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I have previously written on the Supreme Court’s grant of certiorari in CIC Servs., LLC v. IRS , 925 F.3d 247 (6th Cir. 2019), reh., en banc...
Monday, November 23, 2020

My Suggestions to Tax Court on Procedure Related Matters (11/23/20)

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On September 1, 2020, I sent the Tax Court Clerk a letter with suggestions regarding matters related somewhat to tax procedure.  A copy of t...

More Coca-Cola - On Transfer Pricing and Blocked Income Regulation (11/23/20)

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I recently wrote on burden of proof issues in The Coca-Cola Company v. Commissioner , 155 T.C. ___, No. 10 (2020), here .  Tax Court (Judge ...
Thursday, November 19, 2020

Tax Court (Judge Lauber) Issues Significant Transfer Pricing Decision in Coca-Cola; Burden of Proof Issues (11/19/20; 11/25/20)

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Yesterday, the Tax Court decided The Coca-Cola Company v. Commissioner , 155 T.C. ___, No. 10 (2020), GS  here , a transfer pricing company ...