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You Call That "Notice"? Seriously?
Procedurally Taxing blog (2022)
  • Robert D. Probasco, Texas A&M University School of Law
Abstract
In the General Mills case, the taxpayer argued - to bypass a statute of limitations issue - that the documents it received from the IRS did not constitute a "notice of computational adjustment" under the old TEFRA regime for partnership audits. The Circuit Court of Appeals rejected that argument, but the quality of "notice" to the taxpayer in this instance was substantially inferior to virtually all other types of notice which require a specific type of action within a specific timeframe.
Keywords
  • IRS,
  • General Mills,
  • taxpayer rights,
  • TEFRA,
  • partnership audits,
  • notice of computational adjustment
Disciplines
Publication Date
March 24, 2022
Citation Information
Robert D. Probasco. "You Call That "Notice"? Seriously?" Procedurally Taxing blog (2022)
Available at: http://works.bepress.com/robert-probasco/143/