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TAX RESOLUTION Archive

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.

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

Late Submitted Erroneous Reimbursement Match

TweetShareSharePin0 Shares In United States v. Page, No. 3:20-cv-08072 (D. Ariz. April 16, 2021) the court holds that a big wrong reimbursement the Internal Revenue Service sent out to the taxpayer can not be recouped due to the fact that the Division of Justice submitted the wrong reimbursement fit far too late. The concern of
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