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Tax Lawyer, Vol. 55, No. 2 NO FORKS IN THE ROAD TO REFUNDS 605 605 THE VARIANCE DOCTRINE: NO FORKS IN THE ROAD TO REFUNDS Margaret C. Wilson* I. INTRODUCTION A taxpayer seeking a refund of a federal tax overpayment has a burden of foresight far beyond that placed upon its adversary, the Service, when seeking to recover a deficiency in tax from the taxpayer. The taxpayer’s administrative refund claim constitutes a limiting document in the event the taxpayer ultimately must sue to recover the...

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