The Sixth Circuit has unanimously and summarily denied a Government request for en banc rehearing of a taxpayer-favorable ruling in United States v. Quality Stores, Inc., 693 F.3d 605 (6th Cir. Sept. 7, 2012)....more
- FICA Taxes IRS Quality Stores Refunds Statute of Limitations SUB Wages
The Internal Revenue Service’s Director of Collection Policy recently released Memorandum SBSE-05-0912-075, revising prior guidance to IRS collection employees on their obligations to preserve electronic and paper documents...more
It is boilerplate law that parties are under an obligation to preserve potentially relevant evidence when they identify a “reasonable anticipation of litigation.” Application of that simple rule in the real world is more...more
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