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US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

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US Tax Disputes

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Penalties and Reasonable Cause

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  • Penalties and Reasonable Cause

D.C. Circuit Affirms the Importance of Filling Out Form 8283 Completely

By Jeff Erney
  • Penalties and Reasonable Cause

Thouron v. United States: Third Circuit Holds Reliance on Counsel may Relieve Penalties for Late Payment of Taxes.

By Marc Teitelbaum and John Harrington
  • Partnerships/TEFRA
  • Penalties and Reasonable Cause

SCOTUS Struggles with TEFRA Jurisdiction: Oral Arguments in United States v. Woods

By John Harrington and Marc Teitelbaum
  • Partnerships/TEFRA
  • Penalties and Reasonable Cause

Jurisdiction to Dispute Penalties: Partner v. Partnership-Level Proceedings

By John Harrington and Marc Teitelbaum
  • Penalties and Reasonable Cause

Did the Tax Court Enforce Retroactive Penalties?

By John Harrington and Marc Teitelbaum
  • Partnerships/TEFRA
  • Penalties and Reasonable Cause

The Eighth Circuit Weighs in on Whether Outside Basis is an Affected Item at the Partner Level

By Marc Teitelbaum and John Harrington

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Additional resources

Visit our Global tax guide to doing business in... 2022.

global tax guide 2022
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