Banister, Joe

The purpose of this board is to track the status of activity, cases, and ultimately the incarceration or fines against TP promoters and certain high-profile TPs.
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Dr. Caligari
J.D., Miskatonic University School of Crickets
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Re: Banister, Joe

Postby Dr. Caligari » Fri Aug 12, 2016 4:14 am

(3) who knows that such portion (if so used) would result in an understatement of the liability for tax of another person,

Banister's argument is that a CDP hearing only determines if a levy can take place, and thus cannot result in an understatement of liability. I'm not sure if that argument is a winner, but it's not nuts. (And it may, as you suggest, make a difference whether or not it is a post-Notice of Deficiency CDP Hearing, since liability isn't even discussed at a CDP Hearing if the taxpayer received an NOD.)
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