Mitigation of the SOL on refund claims. (statute of limitations): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on May 1, 1997. The length of the article is 609 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: The US Court of Appeals for the Ninth Circuit's ruling in Beaudry Motor Co. demonstrates that the mitigation provisions of IRC sections 1311-1312 are not generally available to taxpayers to cure statute of limitations problems. The mitigation provisions are employed when inconsistent positions, resulting in double inclusion or double deduction, are supported by the IRS or the taxpayer. In Beaudry, the Court denied the taxpayer's untimely refund claim, stating that the taxpayer should have been aware of the consequences of a subsequent return position.

Citation Details
Title: Mitigation of the SOL on refund claims. (statute of limitations)
Author: Boyd D. Hudson
Publication:The Tax Adviser (Magazine/Journal)
Date: May 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n5 Page: 289(2)

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