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Expert Analysis

Flawed Analysis Supports Common Law Tax Deficiency Ruling

By Loren Opper and Christie Galinski (July 11, 2023, 5:10 PM EDT) -- In June, the U.S. District Court for the District of Colorado ruled in the high profile case Liberty Global Inc. v. U.S.,[1] that the U.S. Department of Justice may rely on common law rather than the Internal Revenue Code's statutory notice of tax deficiency to assert a federal income tax deficiency.[2]...

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