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TEFRA + LCU = Confusion, Part 1

We invite back guest blog writer Bob Probasco for a three-part collection influenced by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement insurance claim as unforeseen under TEFRA, although the case would certainly have been prompt under the common durations of area 6511. Component 1 establishes the phase and also analyzes the bulk’s thinking. § 301.6231(a)( 6 )-1(b) particularly consisted of passion in the extent of computational modifications and also GMI did not test the credibility of the policy.

We invite back guest blog writer Bob Probasco for a three-part collection influenced by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement case as unexpected under TEFRA, although the case would certainly have been prompt under the common durations of area 6511. Component 1 establishes the phase and also checks out the bulk’s thinking. Treas. Reg. The bulk’s reaction: Treas. Reg. § 301.6231(a)( 6 )-1(b) especially consisted of rate of interest in the range of computational changes and also GMI did not test the legitimacy of the policy.

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