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TEFRA + LCU = Confusion, Part 1

We invite back guest blog owner Bob Probasco for a three-part collection influenced by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement case 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 range of computational changes as well as GMI did not test the legitimacy of the guideline.

We invite back guest blog owner Bob Probasco for a three-part collection motivated by the Federal Circuit’s current 2-1 choice throwing General Mills’ reimbursement case as unexpected 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. Treas. Reg. The bulk’s reaction: Treas. Reg. § 301.6231(a)( 6 )-1(b) particularly 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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