Menu

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 case as unfortunate under TEFRA, although the insurance claim would certainly have been prompt under the basic 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 changes as well as 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 conventional durations of area 6511. Component 1 establishes the phase as well as checks out the bulk’s thinking. Treas. Reg. The bulk’s feedback: Treas. Reg. § 301.6231(a)( 6 )-1(b) particularly consisted of passion in the extent of computational changes as well as GMI did not test the legitimacy of the guideline.

Leave a Reply

Your email address will not be published. Required fields are marked *