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The Nuts And Bolts Of Deficiency Cases: From Examination ...
I. IRS Examination A. How A Return Is Selected • Matching Programs/DIF Score. ... assets and U.S. report-ing requirements in connection with their ... partment of Justice, and other federal and state government regulators. The Nuts And Bolts Of Deficiency Cases: From Examination To The Tax Court. 26 | The Practical Tax Lawyer Fall 2012 ...
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Case: 3:11-cv-00626-bbc Document #: 56 Filed: …
www.capdale.comin the united states district court for the western district of wisconsin
Procedural Considerations in Addressing Chapter …
www.capdale.com5 | P a g e www.caplindrysdale.com Normally, a given transaction generates a single act of self-dealing. However, where the transaction is the lending of money, lease of property, or other use of foundation property, it is treated as giving rise to an act of self-
INTERNATIONAL DEVELOPMENTS Taxation of Passive …
www.capdale.comgross income for the year is passive or investment-type income (“income test”), or (2) at least 50% of the average fair market value of its assets during the year are assets that produce or are held for the production of passive income (“asset test”).4 For purposes of these tests, passive
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