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Brought To You By Dentons. Vox Tax: Global Protections for Tax Advice. Posted on Jan 5th, 2015. Shortly before the end of 2014, Dentons published a new edition of Vox Tax. This edition of Vox Tax analyzes global protections available for tax advice and provides a high-level overview of legal privileges and protections that may preclude the production of sensitive tax advice in administrative tax examinations and judicial proceedings. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. 9th Cir&#...

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US Tax Disputes | Brought To You By Dentons | ustaxdisputes.com Reviews

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Brought To You By Dentons. Vox Tax: Global Protections for Tax Advice. Posted on Jan 5th, 2015. Shortly before the end of 2014, Dentons published a new edition of Vox Tax. This edition of Vox Tax analyzes global protections available for tax advice and provides a high-level overview of legal privileges and protections that may preclude the production of sensitive tax advice in administrative tax examinations and judicial proceedings. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. 9th Cir&#...

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US Tax Disputes | Brought To You By Dentons | ustaxdisputes.com Reviews

https://ustaxdisputes.com

Brought To You By Dentons. Vox Tax: Global Protections for Tax Advice. Posted on Jan 5th, 2015. Shortly before the end of 2014, Dentons published a new edition of Vox Tax. This edition of Vox Tax analyzes global protections available for tax advice and provides a high-level overview of legal privileges and protections that may preclude the production of sensitive tax advice in administrative tax examinations and judicial proceedings. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. 9th Cir&#...

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The Ninth Circuit Holds Equitable Recoupment Not Time-Barred | US Tax Disputes

http://www.ustaxdisputes.com/the-ninth-circuit-holds-equitable-recoupment-not-time-barred

Brought To You By Dentons. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. Posted on Dec 2nd, 2014. In a taxpayer win, the Ninth Circuit recently reversed the Tax Court and held equitable recoupment was not time barred. Revah v. Comm’r. Menard, Inc. v. Comm’r. 130 TC. 54. At 62-63. In practice, taxpayers often have difficulty mounting arguments of equitable recoupment against the IRS, although the Government typically has more success in this area. Receive our latest blog posts by email.

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Refund Claims | US Tax Disputes

http://www.ustaxdisputes.com/category/refund-claims

Brought To You By Dentons. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. Posted on Dec 2nd, 2014. In a taxpayer win, the Ninth Circuit recently reversed the Tax Court and held equitable recoupment was not time barred. Revah v. Comm’r. Menard, Inc. v. Comm’r. 130 TC. 54. At 62-63. In practice, taxpayers often have difficulty mounting arguments of equitable recoupment against the IRS, although the Government typically has more success in this area. Posted on Oct 30th, 2014. The Supreme Cour...

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Marc Teitelbaum | US Tax Disputes

http://www.ustaxdisputes.com/author/mteitelbaum

Brought To You By Dentons. Vox Tax: Global Protections for Tax Advice. Posted on Jan 5th, 2015. Shortly before the end of 2014, Dentons published a new edition of Vox Tax. This edition of Vox Tax analyzes global protections available for tax advice and provides a high-level overview of legal privileges and protections that may preclude the production of sensitive tax advice in administrative tax examinations and judicial proceedings. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. 9th Cir&#...

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Who We Are | US Tax Disputes

http://www.ustaxdisputes.com/who-we-are

Brought To You By Dentons. 1 202 496 7251. Jim Mastracchio is a seasoned advocate who chairs Dentons’ US Tax Controversy practice and Criminal Tax practice. 1 202 496 7252. Jennifer is a member of Dentons' Litigation and Dispute Resolution and Tax Litigation and Dispute Resolution practices in the Washington, DC office. 1 212 768 6749. Marc Teitelbaum is the chair of Dentons' US Tax practice, which was recognized by. In 2015 for outstanding work in international tax. 1 202 496 7253. The accounting profes...

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John Harrington | US Tax Disputes

http://www.ustaxdisputes.com/author/jharrington

Brought To You By Dentons. Vox Tax: Global Protections for Tax Advice. Posted on Jan 5th, 2015. Shortly before the end of 2014, Dentons published a new edition of Vox Tax. This edition of Vox Tax analyzes global protections available for tax advice and provides a high-level overview of legal privileges and protections that may preclude the production of sensitive tax advice in administrative tax examinations and judicial proceedings. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. 9th Cir&#...

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federaltaxprocedure.blogspot.com

Federal Tax Procedure: Estate Did Not Have Reasonable Cause For Failure to Timely File Estate Tax Return (4/11/13)

http://federaltaxprocedure.blogspot.com/2013/04/estate-did-not-have-reasonable-cause.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Thursday, April 11, 2013. 713 F3d 1164 (9th Cir. 2013), here. Extensions of the...

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Two Courts' Approaches to Taxpayer Culpability in the Son-of-Boss Bullshit Tax Shelter (3/26/15)

http://federaltaxprocedure.blogspot.com/2015/03/two-courts-approaches-to-taxpayer.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Thursday, March 26, 2015. 144 TC. No. 11 (2015), here. And appeal, here. Which ...

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Transferee-of-Transferee Liability (4/4/13)

http://federaltaxprocedure.blogspot.com/2013/04/transferee-of-transferee-liability-4413.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Thursday, April 4, 2013. In Frank Sawyer Trust of May 1992 v. Commissioner.

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Statutes of Limitations on Refund Claims - Complexities (6/9/13)

http://federaltaxprocedure.blogspot.com/2013/06/statutes-of-limitations-on-refund.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Saturday, June 8, 2013. In my book, I use various examples to illustrate the ap...

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Good Advice for Studying the Law - Highly Recommended

http://federaltaxprocedure.blogspot.com/p/good-advice-for-studying-law-highly.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Good Advice for Studying the Law - Highly Recommended. For the course materials:.

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Leading Tax Procedure Cases (In Process)

http://federaltaxprocedure.blogspot.com/p/leading-tax-procedure-cases.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Leading Tax Procedure Cases (In Process). Badaracco v. Commissioner. Held that ...

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Seventh Circuit Opinion on Role of Notice of Deficiency and Last Known Address Requirement (3/7/15)

http://federaltaxprocedure.blogspot.com/2015/03/seventh-circuit-opinion-on-role-of.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Saturday, March 7, 2015. In Gyorgy v. Commissioner. Gyorgy's main complaint is ...

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Court Rejects Duty of Clarity Argument Where IRS Had Provided Clarity (3/26/15)

http://federaltaxprocedure.blogspot.com/2015/03/court-rejects-duty-of-clarity-argument.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Thursday, March 26, 2015. In Bombardier Aero. Corp. v. United States. 435 US&#4...

federaltaxprocedure.blogspot.com

Federal Tax Procedure: Federal Tax Procedure Book 2015 Errata (8/5/15)

http://federaltaxprocedure.blogspot.com/p/federal-tax-procedure-book-2014-errata.html

This blog will update Jack Townsend's Federal Tax Procedure Book 2016 - Student ed. (no footnotes) and Practitioner ed. (footnotes), both available free from SSRN (linked below). Jack started publishing these books while teaching Federal Tax Procedure at University of Houston Law School (through Fall 2015). Jack continues those publications with updates and errata on this blog pending the next publication date in August 2017. Federal Tax Procedure Book 2015 Errata (8/5/15). Subscribe to: Posts (Atom).

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US Tax Disputes | Brought To You By Dentons

Brought To You By Dentons. Vox Tax: Global Protections for Tax Advice. Posted on Jan 5th, 2015. Shortly before the end of 2014, Dentons published a new edition of Vox Tax. This edition of Vox Tax analyzes global protections available for tax advice and provides a high-level overview of legal privileges and protections that may preclude the production of sensitive tax advice in administrative tax examinations and judicial proceedings. The Ninth Circuit Holds Equitable Recoupment Not Time-Barred. 9th Cir&#...

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