Steve R. Johnson
Florida State University - College of Law
July 20, 2009
State Tax Notes, Vol. 53, No. 169, 2009
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: 12Accepted Paper Series
Date posted: September 18, 2009
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