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BASR Partnership - US Court of Appeals for the Federal Circuit

www.cafc.uscourts.gov/sites/default/files/opinions-orders/14-5037.Opinion.7-27-2015.1.PDF

Jul 29, 2015 ... BASR PARTNERSHIP v. US. 3. 1999 tax return. The Claims Court disagreed and held that § 6501(c)(1)'s suspension of the three-year ...

Whose Intent to Evade Tax Is It? | Publications | Thought Leadership ...

www.mwe.com/de/thought-leadership/publications/2015/08/whose-intent-to-evade-tax-is-it

Aug 5, 2015 ... On July 29, 2015, the Federal Circuit, rejecting the Tax Court's decision in Allen v. Commissioner, 128 T.C. 37 (2007), held in BASR Partnership ...

BASR PARTNERSHIP v. US , No. 14-5037 (Fed. Cir ... - Justia Law

law.justia.com/cases/federal/appellate-courts/cafc/14-5037/14-5037-2014-04-16.html

BASR PARTNERSHIP v. US , No. 14-5037 (Fed. Cir. 2014) case opinion from the U.S. Court of Appeals for the Federal Circuit.

IRS Says Lawyer's Fraud Doesn't Trigger Statute Of Limitations ...

www.law360.com/articles/601780/irs-says-lawyer-s-fraud-doesn-t-trigger-statute-of-limitations

Dec 4, 2014 ... In its de novo appeal to the Federal Circuit, the IRS said BASR's argument to ... The BASR Partnership is represented by Thomas A. Cullinan of ...

IRS Must Abide By 3-Year Limit In Jenkens Tax Fraud Case - Law360

www.law360.com/articles/685160/irs-must-abide-by-3-year-limit-in-jenkens-tax-fraud-case

Jul 30, 2015 ... The IRS issued a Final Partnership Administrative Adjustment to BASR Partnership in 2010, which was set up by the Pettinati family's lawyer to ...

T&K Tax Knowledge: Tax Shelters

www.tktaxknowledge.com/tax-shelters/

Aug 3, 2015 ... ... Tax Report article (subscription required) about a July 29 opinion by the U.S. Court of Appeals for the Federal Circuit in BASR Partnership v.

Court of Appeals for the Federal Circuit Holds that Fraud by a Third ...

taxlitigator.me/2015/08/03/court-of-appeals-for-the-federal-circuit-holds-that-fraud-by-a-third-party-does-not-extend-the-statute-of-limitations-by-lacey-strachan/

Aug 3, 2015 ... In BASR Partnership, William F. Pettinati, Sr., Tax Matters Partner v. United States , No. 2014-5037 (Fed. Cir. July 29, 2015), the Court of ...

Courts Split on Question of Who Must Have Fraudulent Intent to ...

ascpa.wordpress.com/2013/10/16/courts-split-on-question-of-who-must-have-fraudulent-intent-to-trigger-unlimited-statute-on-assessing-tax/

Oct 16, 2013 ... The Court of Claims voiced its contrary opinion, specifically rejecting the City Wide Transit and Allen analysis in the case of BASR Partnership v ...

Current Developments in Partners and Partnerships - The Tax Adviser

www.thetaxadviser.com/issues/2014/feb/burton-feb2014.html

In BASR Partnership, the taxpayer filed a petition for a readjustment of taxes and a refund of federal taxes paid because, it asserted, an FPAA was time-barred by ...

Taxpayer's Statute of Limitations Isn't Extended by Third Party's ...

www.parkertaxpublishing.com/public/taxpayer-statute-limitations-evade-tax.html

Sep 3, 2015 ... BASR Partnership v. U.S., 2015 PTC 263 (Fed. Cir. 2015). Background. In 1999, the members of the Pettinati family were about to realize a ...

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Court of Federal Claims Rules Adviser Fraud Does Not Extend ...

www.mwe.com

Oct 17, 2013 ... On September 30, 2013, the U.S. Court of Federal Claims held in BASR Partnership v. United States, No. 10-244 (Fed. Cl. 2013), that ...

Federal Tax Crimes: Court of Federal Claims Holds that Unlimited ...

federaltaxcrimes.blogspot.com

Oct 3, 2013 ... BASR Partnership v. United States, 113 Fed. Cl. 181 (9/30/13 Filed; As Revised 10/29/13), here, the Court of Federal Claims (Judge Susan G.

Taxpayer Advocate Reports On Top 10 Most Litigated Tax Issues ...

www.forbes.com

Jan 15, 2015 ... NTA also called out BASR Partnership. In BASR Partnership v. United States, the Court of Federal Claims held that a tax preparer's fraud could ...