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Divisibility of Section 6708 Penalty Allows (Slightly) Easier Access to District Courts  


Author:  John Ensminger.


Source: Volume 20, Number 03, January/February 2007 , pp.62-64(3)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

In PLR 200646016, the IRS considered whether penalties assessed under Section 6708 were divisible for purposes of establishing refund suit jurisdiction, and concluded that they were.

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