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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
- Tax News & Comment — May 2016 May 14, 2016
- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
Most Popular
- Executor and Trustee Commissions Under NY EPTL
- Rev. Rul. 85-13: Is There a Limit to Disregarding Disregarded Entities?
- Distributable Net Income and Income in Respect of a Decedent
- Legal Basis for Seeking Abatement of New York State Tax Penalties
- Requirement of Filing Federal Gift Tax Return
- Depreciation Recapture
- Income Tax Planning for New York Trusts
- Qualified Personal Residence Trusts (QPRTs)
- Defeating The Right of Election in EPTL § 5-1.1-A
- Article 78 Appeals to Appellate Division, Third Department
Tag Archives: notice of deficiency
Federal Tax Litigation
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
Posted in Federal Tax Litigation, News, Treatises
Tagged 90 day letter, Claims for Refund, collateral estoppel, equitable estoppel, golson doctrine, IRS appeals, notice of deficiency, refund litigation, refund litigation in district court, res judicata, settlement, tax court litigation, tax court rules
IRS Audit Procedures
PDF format: IRS Audit Procedures.wpd The process used to select returns for audit is not a random one. The oft-repeated phrase “audit lottery” is in many ways misleading since certain items, such as claiming a loss on the sale of … Continue reading
Posted in IRS, IRS Audits
Tagged 90 day letter, Appeals Office, audit, claim for refund, deficiency, IRS Audit, notice of deficiency, statute of limitations
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