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Ruling was revoked as soon as -60this error came to the Commissioner s attention. See Priv. Ltr. Rul. 7805020 Sept. 958-1 b Income Tax Regs. providing that a CFC owned by a foreign grantor trust is treated as owned by the grantor. See Taproot Admin. Servs. Inc. v. Commissioner 679 F.3d 1109 1115 n.14 9th Cir. 2012 aff g 133 T. C. This explanation satisfied Longboard. After getting Longboard s signoff on the security agreement Mr. 144 T. C. No* 17 UNITED STATES TAX COURT JEFFREY T. WEBBER...
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So I want to talk about Tax Court what is Tax Court how do you end up there and what do you do when you get there and how do you get there, so Tax Court is basically the court that has original jurisdiction over IRS matters both in examination and the collection division to a much lesser extent in the collection division so the examination division what is that well the examination division is the division of the IRS that attempts to determine how much tax you owe so think of it as the audit examine or the audit division so how do you end up in tax court well your typical way to end up in Tax Court is you're going through an audit and your auditor, and you just can't seem to agree, so the auditor wants to disallow a bunch of stuff and you as a taxpayer just don't think it's right and that's rEval common so what will happen is eventually the auditor will run out of time will start to run out of time on what's called the assessment statute of limitations in a nutshell they have three yea

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