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Full-Text Articles in Law
Shelf Project: Amended Returns -- Imposing A Duty To Correct Material Mistakes, T. Keith Fogg, Calvin H. Johnson
Shelf Project: Amended Returns -- Imposing A Duty To Correct Material Mistakes, T. Keith Fogg, Calvin H. Johnson
T. Keith Fogg
The amended returns proposal would create a duty for a taxpayer to correct material factual errors on its tax return when the error is discovered. Failure to correct an erroneous but innocent representation is considered to be a form of deceit in American tort and contract law.
Shelf Project: National Tax Lien Registry, T. Fogg
Shelf Project: National Tax Lien Registry, T. Fogg
T. Keith Fogg
The current system for filing a notice of federal tax lien came into existence before the electronic age. It relies on myriad state laws and the filing of notices in localities more than 4,100 in all. The current system hurts both the IRS and taxpayers by requiring multiple filings and, thus, multiple removals when the underlying obligation is paid or discharged. With increasing complexity comes increasing costs and errors for the IRS, taxpayers, and taxpayers' creditors. A single Web-based system would be cheaper and more efficient. That possibility drives this recommendation.