duty of consistency
Court Affirms Broad Scope of the Duty of Consistency
The IRS can use the duty of consistency doctrine to disallow tax deductions, credits, etc. in the current year when the deduction, credit, etc. in the current year is based on facts that differ from facts reported to the IRS in an earlier year. In Musa v. Commissioner, No. 16-1841 (7th Cir. 2017), the court agreed […]
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Duty of Consistency Applied to IRS Lawsuit to Collect Unpaid Taxes
Many tax cases are won or lost based on tax procedure issues. The U.S. v. Holmes, Civil Action No. 4:15-cv-00626 (S.D. Texas 2016), case serves as a reminder of this. The case involved a lawsuit filed by the government in the eleventh hour and the duty…
Quotes: The IRS Does Not Have to Be Consistent
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