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TEFRA + LCU = Confusion, Part 1

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 unfortunate under TEFRA, although the insurance claim would certainly have been prompt under the conventional durations of area 6511. Component 1 establishes the phase and also analyzes the bulk’s thinking. § 301.6231(a)( 6 )-1(b) especially consisted of passion in the range of computational modifications and also 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 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 and also takes a look at the bulk’s thinking. Treas. Reg. The bulk’s action: Treas. Reg. § 301.6231(a)( 6 )-1(b) especially consisted of passion in the range of computational changes as well as GMI did not test the legitimacy of the guideline.

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