2024-05-27 Misleading Silences Are Sometimes Fine in Tax

This week we look at:

  • Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder
  • Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years
  • Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund
  • A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid

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