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AND SOURCES OF TAX
ADMINISTRATIVE SOURCES AND AUTHORITIES
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1998 Reform Act 5th Cir additional adjustment administrative agreement amount Appeals Office apply April 15 asserted attorney audit bankruptcy Chapter claim for refund Code collateral estoppel collection Commissioner corporation Court of Federal criminal decision deductions deﬁned determined District Court due date election estate tax examination expedited assessment expired extension ﬁled ﬁling ﬁnal ﬁnancial ﬁnd ﬁrst Form FPAA fraud gift tax income tax income tax return interest IRS’s issue jeopardy assessment joint return levy litigation mailed ment notice of deﬁciency overpayment paid partners partnership items payer payment penalty period person petition private letter rulings Proc procedures reﬂect reporting requesting spouse respect revenue rulings rules Service signiﬁcant speciﬁc spouse’s statute of limitations summons T.C. Memo Tax Court tax liability tax lien Tax Notes tax return taxable taxpayer termination assessment tion transactions transfer underpayment understatement United