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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 unexpected under TEFRA, although the insurance claim 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. § 301.6231(a)( 6 )-1(b) especially consisted of passion in the range of computational changes as well as GMI did not test the credibility of the law.

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 case as unfortunate under TEFRA, although the case would certainly have been prompt under the common durations of area 6511. Component 1 establishes the phase as well as takes a look at the bulk’s thinking. Treas. Reg. The bulk’s feedback: Treas. Reg. § 301.6231(a)( 6 )-1(b) particularly consisted of passion in the extent of computational changes as well as GMI did not test the legitimacy of the law.

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