Taxpayers may not file a refund suit in federal court unless they have filed an administrative claim with the IRS. In addition, the "substantial variance" rule limits the ability of a taxpayer to recast the refund claim when suit is filed. This post reviews a recent opinion holding that a taxpayer can submit additional evidence in support of a refund claim that was not submitted at the administrative level.
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Tax Law Updates
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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