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Deficient Statutory Notices and the Burdens of Proof: A Reply to Mr. Newton


Leandra Lederman


Indiana University Maurer School of Law


Tax Notes, Vol. 91, No. 16, July 2, 2001

Abstract:     
This article replies to an article written by Anthony Newton. (Tax Notes, May 14, 2001, p. 1139.) Mr. Newton argued that Shea v. Commissioner, 112 T.C. 183 (1999), will help alleviate the burden on taxpayers from uninformative notices of deficiency. This reply contends that although Shea may have reached a correct result in shifting the burden of proof to the IRS, it did so by muddying an important area of the law. In fact, by conflating two procedural rules to reach its decision, the Tax Court may have eliminated the possibility of sanction for some uninformative notices.

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Date posted: September 10, 2004  

Suggested Citation

Lederman, Leandra, Deficient Statutory Notices and the Burdens of Proof: A Reply to Mr. Newton. Tax Notes, Vol. 91, No. 16, July 2, 2001. Available at SSRN: http://ssrn.com/abstract=275492

Contact Information

Leandra Lederman (Contact Author)
Indiana University Maurer School of Law ( email )
211 S. Indiana Avenue
Bloomington, IN 47405
United States
(812) 855-6149 (Phone)
(812) 855-0555 (Fax)
HOME PAGE: http://www.law.indiana.edu/people/lederman
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