Procedurally Taxing: You Call That “Notice”? Seriously? (March 24, 2022)

A guest blogger has made available for download their article, “You Call That “Notice”? Seriously?” published on the Procedurally Taxing blog. The article begins as follows:

Last April, I wrote (see here and here and here) about the Federal Circuit’s decision in General Mills, Inc. v. United States957 F.3d 1275 (Fed. Cir. 2020), aff’g 123 Fed. Cl. 576 (2015).  The briefs on appeal are available here: the taxpayer’s opening brief, the government’s answering brief, and the taxpayer’s reply brief.  This was a complex case, involving the intersection of TEFRA partnership audit procedures and the “large corporate underpayment” (LCU interest, or “hot interest”) provisions of the Code.

There was one argument made by the plaintiff on the TEFRA issue that I addressed rather briefly, because the Federal Circuit simply swatted it away.  That argument really warrants more discussion because it’s a serious problem that goes beyond just this specific context, one that we need to continue challenging: the adequacy of notices to taxpayers.  So let’s talk about that case a bit more.

To see the full article, click here: “You Call That “Notice”? Seriously?”

Posted by Anthony Tran, Associate Editor, Wealth Strategies Journal

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