TEFRA + LCU = Confusion, Part 2Procedurally Taxing blog (2021)
The TEFRA partnership audit rules are confusing. The "large corporate underpayment" interest rules are confusing. When they intersect, it's even worse. That happened in the General Mills decision last year, in which the Federal Circuit rules that the plaintiff's refund suit was filed too late under the applicable TEFRA provision. Part 2 examines the dissent and proposes an alternative framework for analyzing the TEFRA provision at issue.
- hot interest,
- General Mills,
- Federal Circuit
Publication DateApril 28, 2021
Citation InformationRobert D. Probasco. "TEFRA + LCU = Confusion, Part 2" Procedurally Taxing blog (2021)
Available at: http://works.bepress.com/robert-probasco/130/