Stuart J. Bassin

Stuart J. Bassin

BakerHostetler

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Sixth Circuit Denies Government Motion for Rehearing in Quality Stores Employment Tax Challenge

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

2/1/2013 - FICA Taxes IRS Quality Stores Refunds Statute of Limitations SUB Wages

IRS Collection Division Embraces E-Discovery in New Guidance

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

12/10/2012

The Duty to Preserve in Tax Controversies

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

11/20/2012

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