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TEFRA + LCU = Confusion, Part 1

We invite back guest blog owner Bob Probasco for a three-part collection motivated 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 common durations of area 6511. Component 1 establishes the phase as well as analyzes the bulk’s thinking. § 301.6231(a)( 6 )-1(b) particularly consisted of rate of interest in the range of computational modifications and also GMI did not test the legitimacy of the policy.

We invite back guest blog writer Bob Probasco for a three-part collection motivated by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unforeseen under TEFRA, although the insurance claim would certainly have been prompt under the typical durations of area 6511. Component 1 establishes the phase as well as takes a look at the bulk’s thinking. Treas. Reg. The bulk’s action: Treas. Reg. § 301.6231(a)( 6 )-1(b) particularly consisted of rate of interest in the range of computational changes as well as GMI did not test the legitimacy of the guideline.

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