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Pepperdine Law Review

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Full-Text Articles in Law

Redefining “Peril”—Abating The Interest On A Tax Deficiency For Good Faith Reliance On Irs Publications, Brady Cox Feb 2016

Redefining “Peril”—Abating The Interest On A Tax Deficiency For Good Faith Reliance On Irs Publications, Brady Cox

Pepperdine Law Review

Many taxpayers rely on guidance materials the IRS provides in order to comprehend the United States Tax Code and pay an accurate tax. However, many, if not all, of these taxpayers would likely be startled to learn that their reliance on these IRS guidance materials is perilous. That is, that reliance upon these guidance materials will not support a taxpayer’s tax treatment decisions if the IRS decides that the decisions were incorrect under substantive law. However, because the courts have not decisively concluded which financial consequences a taxpayer faces or escapes by relying on informal IRS guidance, “peril” remains undefined. …


Access To Tax Injustice, Francine J. Lipman May 2013

Access To Tax Injustice, Francine J. Lipman

Pepperdine Law Review

Every morning, Monday through Friday, school children across the United States raise their voices in unison and pledge allegiance to America, with liberty and justice for all. America, in turn, pledges to these children and the world that it is a nation of liberty, justice, and laws. Laws drafted by representatives intended to follow through on America’s promise of liberty and justice for all. Yet for more than 16 million of these children and 30 million adults living in poverty in 2011, America does not deliver on its promise of justice. In a recent global study, America ranked 27th out …


Indopco, Inc. V. Commissioner: National Starch Isn't The Only One "Stiffed" By The Supreme Court's Decision, Jeffrey Gates Davis Nov 2012

Indopco, Inc. V. Commissioner: National Starch Isn't The Only One "Stiffed" By The Supreme Court's Decision, Jeffrey Gates Davis

Pepperdine Law Review

No abstract provided.


How Long Can This Go On? The Controversy Over The Application Of The Statute Of Limitations To S Corporations And Their Shareholders, J. Marcus Sommers Nov 2012

How Long Can This Go On? The Controversy Over The Application Of The Statute Of Limitations To S Corporations And Their Shareholders, J. Marcus Sommers

Pepperdine Law Review

No abstract provided.