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Tuesday, September 27, 2022

11th Circuit Holds that a Taxpayer Motion for Injunctive-Type Relief in a Closed Case Is Not Subject to § 7421(a), the AIA (9/27/22)

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In United States v. Meyer , 50 F.4th 23  (11th Cir. 9/26/22), CA11 here  and GS here , the Court outlines the issue in its opening paragraph...
Tuesday, September 20, 2022

Eleventh Circuit Makes Clarity from Confusion as to the Written Supervisor Approval in § 6751(b) (9/20/22)

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In Kroner v. Commissioner , 48 F.4th 1272 (11th Cir. 9/13/22), CA11 here and GS here , the Eleventh Circuit has become the second Circuit t...
Sunday, September 11, 2022

Second Circuit NonTax Opinion on Glitches in the Appellate Process with JAT War Story (9/11/22)

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Most readers of this Federal Tax Procedure Blog do not have such tunnel vision that developments outside the tax procedure area are ignored....
Monday, September 5, 2022

Freeman International Tax Law Symposium October 20 & 21 (9/5/22)

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The following international tax program may be of interest to FTPB readers:  Freeman Law International Tax Symposium (link for information a...
Thursday, September 1, 2022

Tax Court Sustains Accuracy-Related Penalty for Offshore Accounts, Rejecting Taxpayer's QAR, Statute of Limitations, and § 6751(b) Arguments (9/1/22)

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  This blog will alert readers of a new Tax Court opinion,   Lamprecht v. Commissioner , T.C. Memo. 2022-91, involving the accuracy-related ...
Saturday, August 27, 2022

Eaton Wins Big on Appeal in Long-Running Contentious Litigation Over APAs (8/27/22)

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In Eaton Corp. v. United States , 47 F.4th 434 (6th Cir 8/25/22), here  and GS here , the Court gave Eaton a victory on all points of conten...
Saturday, August 20, 2022

Transfer Pricing: Finite Valuation and Ranges (8/20/22)

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          I have just started reading a tax, more or less, history, at least anecdotal history. Michael Keen, & Joel Slemrod, Rebellion,...
Monday, August 15, 2022

Chevron Deference: Much Ado About Not Much (8/15/21)

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This is my third offering on the most recent D.C. Circuit opinion in Guedes v. ATF , 920 F.3d 1 (D.C. Cir. 8/9/22), DCCir  here ,  and GS  h...
Thursday, August 11, 2022

§ 7805(b) Time Limits Do Not Apply to Agency Best Interpretations of the Statute (8/11/22)

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I recently posted a blog on Guedes v. ATF , 45 F.4th 306 (D.C. Cir. 8/9/22), DCCir here ,   and GS here . See Important DC Circuit Opinion T...
Tuesday, August 9, 2022

Important DC Circuit Opinion That Chevron Deference is Irrelevant if Agency Interpretation is Best Interpretation (8/9/22; 8/15/22)

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In Guedes v. ATF , 45 F.4th 306 (D.C. Cir. 8/9/22), DCCir here and GS here , the Court rendered an important decision.  Although it is not ...