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Contract Allocations and Judicial Doctrines

In Cotto-Vázquez v. United States, CIV. NO.: 16-2807 (SCC) (D.P.R. March 11, 2021), Miguel Ángel Cotto-Vázquez (Cotto),1 the former four-time Puerto Rican boxing champion, became involved in another fight. This time he faced...more

When Is a Tax Return "Filed"?

In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

IRS COVID-19 Extensions of Time Provide Relief to Taxpayers

The Internal Revenue Service (IRS) has provided taxpayers with needed relief by delaying the due dates with respect to various filings and payments during the coronavirus (COVID-19) pandemic. This relief has been announced in...more

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