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Separation of Powers Government Agencies Tax Liability

Snell & Wilmer

California Office of Tax Appeals Cleared To Consider Whether Tax Regulations Conflict With Statutes

Snell & Wilmer on

The California Attorney General (AG) recently issued Legal Opinion No. 23-701 stating that the California Office of Tax Appeals (OTA) has the authority to determine whether tax regulations issued by the Franchise Tax Board...more

Miller Canfield

Is the Chief of IRS Appeals Constitutionally Appointed?

Miller Canfield on

The United States Tax Court skillfully dodged answering the headline question with a holding on standing. The court decided, however, that IRS appeals officers and IRS appeals team managers are not officers of the United...more

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