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Complications With Rolling Credit Elect Transfers - Part 1
Procedurally Taxing blog (2021)
  • Robert D. Probasco, Texas A&M University School of Law
Abstract
How do you safeguard against underpayment interest if the IRS may audit you and assert a deficiency? A deposit is one obvious option. These taxpayers tried another approach and the district court concluded that didn't work. Now it is headed to the Fifth Circuit.
Keywords
  • tax,
  • interest,
  • underpayment interest,
  • credit transfer,
  • credit elect transfer,
  • Avon Products,
  • FleetBoston,
  • Goldring
Disciplines
Publication Date
February 4, 2021
Citation Information
Robert D. Probasco. "Complications With Rolling Credit Elect Transfers - Part 1" Procedurally Taxing blog (2021)
Available at: http://works.bepress.com/robert-probasco/120/