Tax Notes Quotes Charles Ruchelman on COFC Program Hosted by Caplin & Drysdale

Tax Notes

Charles M. Ruchelman moderated a program focusing on litigation challenges presented by using the Court of Federal Claims as a forum for tax disputes. The program was sponsored by the U.S. Court of Federal Claims Bar Association and hosted at the offices of Caplin & Drysdale. For the complete article, please visit Tax Notes' website.

Excerpt taken from the article.

Charles M. Ruchelman of Caplin & Drysdale said that as a consequence, tax attorneys must have variance in mind when drafting refund claims, ensuring they have all the necessary arguments and facts in a claim from the outset. Tax professionals should be thorough in preparing a claim because taxpayers "may be harmed if this case ends up in court and I didn't apprise the IRS of another possible alternative argument," he said, concluding that the doctrine is a "trap for the unwary."

Ruchelman said that with the general increase in tax cases invoking the Administrative Procedure Act and other non-tax-code relief provisions -- such as the Loving case challenging the IRS's oversight of registered tax return preparers -- those types of claims could "creep into the Court of Federal Claims."


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