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Ninth Circuit to Rule on Timing for Filing a Qualified Amended Return for an...

The taxpayers in Bergmann v. Commissioner are appealing an adverse Tax Court decision, 137 T.C. No. 10, holding that they failed to timely file a qualified amended return for 2001 and thus are liable...

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Briefing Complete in Bergmann

The Bergmanns participated in a listed transaction promoted by KPMG, known as the Short Option Strategy.  When the Bergmanns filed their amended return in March 2004, the IRS had already served KPMG...

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Oral Argument Scheduled in Bergmann

We have previously reported on the Ninth Circuit’s consideration of the qualified amended return regulation in the Bergmann case.  Several months after the close of the briefing, the court has now...

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Ninth Circuit Refers Bergmann Case to Mediation After Oral Argument

In a somewhat unusual move, the Ninth Circuit issued an order last week suggesting that the parties pursue mediation in the Bergmann case.  The order came two days after the court heard oral argument....

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Ninth Circuit Consideration of Bergmann Is Back On

A court can lead the parties to mediation, but can’t make them drink.  We reported last month that, after oral argument, the Ninth Circuit had suspended its consideration of the Bergmann case so that...

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Ninth Circuit Sides with Government’s Interpretation of QAR Regulations in...

That didn’t take long.  Less than two weeks after learning that the parties would not be mediating their dispute (see our previous report here), the Ninth Circuit issued a brief five-page unpublished...

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Ninth Circuit to Rule on Timing for Filing a Qualified Amended Return for an...

The taxpayers in Bergmann v. Commissioner are appealing an adverse Tax Court decision, 137 T.C. No. 10, holding that they failed to timely file a qualified amended return for 2001 and thus are liable...

View Article

Briefing Complete in Bergmann

The Bergmanns participated in a listed transaction promoted by KPMG, known as the Short Option Strategy.  When the Bergmanns filed their amended return in March 2004, the IRS had already served KPMG...

View Article


Oral Argument Scheduled in Bergmann

We have previously reported on the Ninth Circuit’s consideration of the qualified amended return regulation in the Bergmann case.  Several months after the close of the briefing, the court has now...

View Article


Ninth Circuit Refers Bergmann Case to Mediation After Oral Argument

In a somewhat unusual move, the Ninth Circuit issued an order last week suggesting that the parties pursue mediation in the Bergmann case.  The order came two days after the court heard oral argument....

View Article

Ninth Circuit Consideration of Bergmann Is Back On

A court can lead the parties to mediation, but can’t make them drink.  We reported last month that, after oral argument, the Ninth Circuit had suspended its consideration of the Bergmann case so that...

View Article

Ninth Circuit Sides with Government’s Interpretation of QAR Regulations in...

That didn’t take long.  Less than two weeks after learning that the parties would not be mediating their dispute (see our previous report here), the Ninth Circuit issued a brief five-page unpublished...

View Article
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