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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
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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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