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BASR PARTNERSHIP v. US - US Court of Appeals for the Federal ...

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

Jul 29, 2015 ... tax return filed by plaintiff-appellee BASR Partnership. (BASR). ... limitation on the IRS's ability to assess and impose tax on BASR for the ...

Federal Tax Crimes: BASR Briefs On Issue of Unlimited Statute of ...

federaltaxcrimes.blogspot.com/2014/08/basr-briefs-on-issue-of-unlimited.html

Aug 26, 2014 ... In BASR Partnership v. United States, 113 Fed. Cl. 181 (9/30/13 Filed; As Revised 10/29/13), here, the Court of Federal Claims rejected Allen ...

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 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 ...

IRS Loses Bid For Rehearing Of Jenkens Tax Fraud Case - Law360

www.law360.com/articles/726362/irs-loses-bid-for-rehearing-of-jenkens-tax-fraud-case

Nov 12, 2015 ... The case is BASR Partnership, William F. Pettinati Sr., tax matters partner v. U.S., case number 14-5037, in the U.S. Court of Appeals for the ...

Fraudulent Tax Returns and the Statute of Limitations

wealthmanagement.com/high-net-worth/fraudulent-tax-returns-and-statute-limitations

Mar 10, 2016 ... However, in a recent case, BASR Partnership v. United States, the U.S. Court Appeals for the Federal Circuit issued a taxpayer-favorable ...

Court of Federal Claims Holds that Agent's Fraud Does Not Extend ...

procedurallytaxing.com/court-of-federal-claims-holds-that-agents-fraud-does-not-extend-statute-of-limitations/

Oct 4, 2013 ... Earlier this week, the Court of Federal Claims in BASR v. .... say that a fraudulent disclosure on a partnership return is attributed to a partner for ...

Current Developments in Partners and Partnerships - The Tax Adviser

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

Jan 31, 2014 ... 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 ...

Significant Cases - Taxpayer Advocate Service

www.taxpayeradvocate.irs.gov/Media/Default/Documents/2014-Annual-Report/Significant-Cases.pdf

Partnership Administrative Adjustment (FPAA).3 In September and October 2010, ...... The BASR partnership entered into a tax shelter that it and its partners ...

Preparing for preparer fraud: A practitioner's guide - Osler, Hoskin ...

www.osler.com/osler/media/Osler/reports/taxation/Preparing-for-preparer-fraud-A-practitioners-guide.pdf

Jul 4, 2016 ... mitted fraud), with BASR Partnership, 795 F.3d 1338, 1339-1357, aff'g 113 Fed. Cl. 181 (rejecting Allen's doctrine of preparer fraud). 8Loving v.

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

www.mwe.com

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. United States | Legacy Advisors

www.gtlaw-legacyadvisors.com

Aug 23, 2016 ... A fraudulent tax return is bad news for a taxpayer. Normally, the IRS has a limited period of time (3 years) to audit a taxpayer's return.

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 ...