Tag Archives: Claims for Refund

Federal Tax Litigation

Posted on February 18, 2015 by David L. Silverman, J.D., LL.M. (Taxation)

I. Introduction In general, the statute of limitations for the IRS to assess is three years after the date the return is filed or two years from the date the tax is paid. After audit, the IRS may issue a … Continue reading →

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2012 Gift & Estate Tax Decisions of Note

Posted on February 14, 2013 by David L. Silverman, J.D., LL.M. (Taxation)

View in PDF:  Tax News & Comment — February 2013 2012 Gift & Estate Tax Decisions of Note I.    Formula Clauses The Tax Court in Wandry v. Com’r, T.C. Memo 2012-88, nonacq., 2012-46 I.R.B. upheld a defined value clause containing … Continue reading →

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