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- Issue for the New Partnership Audit Procedures Raised in TEFRA Case
- Penalty Abatement for Reliance on Tax Advisor Who Made Obvious Errors
- Wholly Owned Corp and Parent Not the “Same Corporation” for Interest Netting
- Two Years to File Refund Suit in District Court, Six Years in Federal Court of Claims
- Ninth Circuit Says Taxpayer Must Use IRS Form
- Court Affirms Broad Scope of the Duty of Consistency
- IRS Must Refund Penalties Despite Tax Malpractice Recovery
- U.S. Foreign Tax Credit Not Impacted by Repayment of Foreign Tax Refund
- Court Considers Economic Substance in S Corp Transactions
- IRS Says Personal Expenses Paid by S Corp. Not Loan Repayments
- Reckless Conduct Sufficient for FBAR Civil Tax Penalty
- Court Says Employer Entitled to Worker’s IRS Records