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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 ...

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

www.mwe.com/en/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 ...

Fed. Circ. Fraud Ruling No Sure Thing For Taxpayers - Law360

www.law360.com/tax/articles/687047/fed-circ-fraud-ruling-no-sure-thing-for-taxpayers

Aug 4, 2015 ... The appellate court on July 29 ruled against the government in a 2-1 decision in BASR Partnership v. U.S., saying the IRS must abide by the ...

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?article_related_content=1

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 ...

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 ...

Taxpayer Advocate Reports On Top 10 Most Litigated Tax Issues

www.forbes.com/sites/kellyphillipserb/2015/01/15/taxpayer-advocate-reports-on-top-10-most-litigated-tax-issues/

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 ...

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.

Fraudulent Tax Returns and the Statute of Limitations

www.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 ...

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 ...

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

federaltaxcrimes.blogspot.com/2013/10/court-of-federal-claims-holds-that.html

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.