TEFRA + LCU = Confusion, Part 1

We invite back guest blog writer Bob Probasco for a three-part collection influenced by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unexpected under TEFRA, although the insurance claim would certainly have been prompt under the conventional durations of area 6511. Component 1 establishes the phase and also takes a look at the bulk’s thinking. § 301.6231(a)( 6 )-1(b) especially consisted of passion in the extent of computational modifications as well as GMI did not test the credibility of the law.

We invite back guest blog owner Bob Probasco for a three-part collection motivated by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unfortunate under TEFRA, although the case would certainly have been prompt under the basic durations of area 6511. Component 1 establishes the phase as well as checks out the bulk’s thinking. Treas. Reg. The bulk’s action: Treas. Reg. § 301.6231(a)( 6 )-1(b) especially consisted of rate of interest in the extent of computational changes and also GMI did not test the legitimacy of the policy.