F1- The Antidote for Rubbing Salt in the Wound: Every Conceivable Defense

While Congress and traditional constitutional principles contemplated that penalties should only be imposed upon a clear violation of a clear standard, the IRS now presumes the application of penalties and often measures them by way of hindsight. And trial courts facing an appeal may not be inclined to undermine their ruling on the merits. We will focus on defenses and strategies in pressing those defenses.

 

Session Information
Session Date:
January 14, 2016
F1- The Antidote for Rubbing Salt in the Wound: Every Conceivable Defense
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Georgia Society of CPAs
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