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End of the Line for Paresky

TweetShareSharePin0 Shares Guest blogger Bob Probasco returns today with perhaps his final update on the Paresky case. Christine Nothing about the decision was really surprising.  The contrary decision in E.W. Scripps Co. v. United States, 420 F.3d 589 (6th Cir. 2005) was always a strained interpretation of the jurisdictional statutes, and the trend has been

Designated Orders, October 5 – 9, 2020

TweetShareSharePin0 Shares Months ago, I heard an interview with the NYU Professor Scott Galloway about what the world may look like post-Covid. One of the main takeaways was to think of the pandemic not as a “change agent,” but rather as “accelerant” of trends that were already underway. I’d say this holds true with the

TEFRA + LCU = Confusion, Part 3

TweetShareSharePin0 Shares In today’s post Bob Probasco concludes his three-part series on General Mills and the intersection of TEFRA and “hot interest.” Part One can be found here. Part Two, here. Christine In Part 1, I described the decision by the Court of the Appeals for the Federal Circuit in General Mills, Inc. v. United

TEFRA + LCU = Confusion, Part 2

TweetShareSharePin0 Shares In Part Two of this three-part series, Bob Probasco examines the dissenting view in the recent General Mills case out of the Federal Circuit. Part One can be found here. Christine In Part 1, I described the decision by the Court of the Appeals for the Federal Circuit in General Mills, Inc. v.

INSTALLMENT AGREEMENT

TweetShareSharePin0 SharesDo I Need One? How Do I Start? Under an installment agreement, the taxpayer agrees to pay the entire amount of their debt in monthly installments over a period of up to six years. This method allows the taxpayer to pay in small, manageable amounts so that the debt is not overwhelming. Once the

TEFRA + LCU = Confusion, Part 1

TweetShareSharePin0 Shares We welcome back guest blogger Bob Probasco for a three-part series inspired by the Federal Circuit’s recent 2-1 decision tossing General Mills’ refund claim as untimely under TEFRA, although the claim would have been timely under the standard timeframes of section 6511. Part 1 sets the stage and examines the majority’s reasoning. Christine
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