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Overview of Federal Tax Controversies
B Return Preparation
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9th Cir addition administrative agency agent agreement amended amount Appeals Officer apply April 15 asserted assessment attorney audit authority burden of proof Chapter Circuit claim for refund client Code section collection Commissioner Congress corporate Counsel Court of Appeals criminal decision deductions defendant determination disclosure discussed District Court documents evidence facts federal tax lien filed FOIA Form income tax return interest Internal Revenue Code Internal Revenue Service IRS Reform IRS's issue jurisdiction lawyer letter ruling levy litigation mailed notice of deficiency opinion overpayment party payment penalty period petition petitioners plaintiffs prepared prior privilege provides reasonable records refund claim regulations request respondent respondent's return information Revenue Procedure Revenue Rulings settlement spouse statement statute of limitations statutory summons supra T.C. Memo Tax Court tax liability tax return tax shelter taxable taxpayer tion transaction Treas trial underpayment United violation