Substantial Compliance

Abstract:     
There are many exceptions to the juvenile saw that “close counts only in horseshoes and hand grenades.” State and local tax practice may be among these exceptions – depending on possible application of the doctrine of substantial compliance. The tax law often makes the legal validity of one action contingent upon a party having taken certain preliminary steps. Strict compliance – having to take those steps in precisely the right way at precisely the right time – is not always necessary. Courts sometimes hold that substantial compliance – “close enough” – suffices. This installment of “Interpretation Matters” discusses the substantial compliance doctrine from three perspectives.

Number of Pages in PDF File: 12

Accepted Paper Series