Menu

TEFRA + LCU = Confusion, Part 1

We invite back guest blog owner Bob Probasco for a three-part collection motivated by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unforeseen under TEFRA, although the insurance claim would certainly have been prompt under the conventional durations of area 6511. Component 1 establishes the phase as well as takes a look at the bulk’s thinking. § 301.6231(a)( 6 )-1(b) especially consisted of rate of interest in the extent of computational modifications as well as GMI did not test the legitimacy of the law.

We invite back guest blog owner Bob Probasco for a three-part collection influenced by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unforeseen under TEFRA, although the case would certainly have been prompt under the common durations of area 6511. Component 1 establishes the phase and also takes a look at the bulk’s thinking. Treas. Reg. The bulk’s reaction: Treas. Reg. § 301.6231(a)( 6 )-1(b) particularly consisted of rate of interest in the range of computational modifications and also GMI did not test the credibility of the policy.

Leave a Reply

Your email address will not be published. Required fields are marked *