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  • 13 years ago
How Much to Tell--Adequate Disclosure and Section 6501(e) - Ed Zollars

How Much to Tell--Adequate Disclosure and Section 6501(e) - Ed Zollars

This PodCast uses the case of Benson v. Commissioner, TC Memorandum 2006-55, to examine the issue of what constitutes adequate disclosure under Section 6501(e)(1)(A)(ii) for purposes of avoiding the otherwise mechanical application of an extended six year statute on substantial underpayments.  In this case, which the taxpayer ends up losing, the Court considers to what extent disclosures on other returns can "make up" for items not disclosed directly on the individual return.The text file for this podcast can be downloaded from http://www.edzollars.com/2006-04-08_Adequate_Disclosure.pdf. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com
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