Beware of Waiving Legal Arguments in Tax Court; You May Not Get a Second Chance to Raise Them – Part 2 of 2
In Part 1 of this article, we discussed a tax case, Boulware v. Commissioner[1], where, at a Tax Court hearing, the Tax Court asked taxpayer’s counsel if he had any legal argument in response to the IRS’s argument that civil fraud penalties should be imposed. Taxpayer’s counsel answered no. Later, following the hearing, taxpayer’s counsel…
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