Estate tax issues add to practice and procedure developments.

The Tax Adviser | October 1, 1998| | Copyright

Tax practice and procedure developments evolve from various types of tax controversies. Recent developments originated in matters involving the calculation or payment of Federal estate taxes but have broad application beyond the estate tax area. In one instance, the IRS National Office issued technical advice that an estate's refund claim was limited to the installments of estate tax actually paid within two years of its filing. In another case, the Tax Court held that, for penalty computation purposes, an estate tax deficiency is based on all deductible expenses, not just ...

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