Popular Press
A Question of Identity - Interest Netting, Part 1
Procedurally Taxing
(2019)
Abstract
Part 1 of an overview and critique of cases interpreting the Internal Revenue Code provision for "netting" tax overpayment and underpayment balances outstanding for the "same taxpayer." What does 'same taxpayer" mean? It's not clear and some of the decisions could have, perhaps should have, come out differently. The overview also provides speculation on how this issue may develop in the future.
Keywords
- tax,
- overpayment interest,
- underpayment interest,
- interest netting,
- same taxpayer
Disciplines
Publication Date
January 8, 2019
Citation Information
Robert D. Probasco. "A Question of Identity - Interest Netting, Part 1" Procedurally Taxing (2019) Available at: http://works.bepress.com/robert-probasco/51/