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Form 870 ND: What You Should Know
That ruling did not hold, however, that the offer to waive restrictions and accept over assessment by a taxpayer does not mean that the person who made the deal is bound by that final ruling in the same way, since the offer can be withdrawn by the claimant. Jun 10, 2023 — Memo 2020-79, on equitable estoppel in respect of Form 870. The issue is whether the agreement is enforceable. If the settlement is enforceable, equitable estoppel does not apply. If the settlement is not enforceable then the final order in the non-docketed case should not hold, because the acceptance of over assessment was not binding. Sep 18, 2023 — Memo 2021-55, The IRS has been in the IRS's Tax Court for over a decade. As such, it may be reasonable to expect that it has developed a substantial understanding of the court's procedures for cases involving tax assessment and tax assessment adjustment. Although other aspects of the court's work have not yet been explained, these developments may be important to the agency's ability to conduct successful Court Case Management, Tax Court Review hearings in tax appeals cases. Jul 15, 2023 — Memo 2022-40, The IRS has developed a reasonable expectation of a favorable outcome, based in part on what it has learned about the process for determining tax assessment adjustments. That expectation is indeed based on knowledge it gains through the Court's review of the IRS's assessments, its knowledge which it gathers from other court proceedings, and from an outside source, that it cannot reveal at this time for its own security purposes. Jul 18, 2023 — Memo 2022-53, The court and IRS have developed a reasonable expectation of a favorable outcome, based in part on what the court has learned about the IRS's case management process. That expectation is still based on knowledge gained through the court proceedings and other court work as it develops. Jul 18, 2023 — Amended Oct.
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