Tax Controversies: Practice and Procedure
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This Tax Controversies: Practice and Procedure also includes several new cases and expanded coverage of summonses, CDP hearings, and other topics. An underlying theme - the extent to which the current procedural rules encourage or discourage voluntary compliance with the federal tax system - runs throughout the book.
Table of Contents includes:
Overview of Federal Tax Controversies;
Tax Returns and the Examination Process;
Access to IRS Information Versus Confidentiality of Taxpayer Information;
Settlement of Tax Disputes;
Restrictions on Assessment of Tax;
Overview of Tax Litigation;
Requirements of the Notice of Deficiency and Its Functions in Tax Court;
Overpayments, Refund Claims, and Refund Litigation;
Reliance on Treasury Regulations and IRS Positions;
Civil Tax Penalties;
Interest on Deficiencies and Overpayments;
Criminal Tax Procedure;
Representing Clients in Tax Cases;
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|Edition||3rd ed., 2009|