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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.