Randolph Herndon Jr.

Randolph Herndon Jr.

McDermott Will & Emery

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Latest Publications


Supreme Court Grapples With Showing Required For Evidentiary Hearing Before Summons Enforcement

After hearing oral arguments in a case alleging the Internal Revenue Service issued summonses for an improper purpose, the Supreme Court of the United States is set to provide guidance on the type of evidence that a summoned...more

4/25/2014 - Evidentiary Hearings IRS SCOTUS Summons

District Court Accords Work Product Protection to Taxpayer Documents Prepared during a Transaction’s Planning Stages

The U.S. District Court for the District of Delaware recently interpreted the work product privilege in a manner favorable to taxpayers, ruling that documents can be prepared “in anticipation of litigation” even if created...more

12/9/2013 - Bank Holding Company Corporate Taxes Discovery Federal Rules of Civil Procedure Income Taxes IRS Rule 26 Work Product Privilege

Court of Federal Claims Rules Adviser Fraud Does Not Extend Three-Year Statute of Limitations Period

The U.S. Court of Federal Claims recently held that third-party fraud committed on a partnership’s tax return did not extend the three-year statute of limitations period for assessment of income taxes, a decision that...more

10/18/2013 - Fraud Income Taxes Investment Adviser Statute of Limitations Tax Returns

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