Form 4549 is not a closing document. taxpayers not entitled to refund of disclosure penalties based on contract theory as there was no form 866 or form 906 closing agreements

Form 4549 is not a closing document. taxpayers not entitled to refund of disclosure penalties based on contract theory as there was no form 866 or form 906 closing agreements
LINK TO ITEM
Code Sec. 7121
HINKLE v. U.S., No. 1:16-cv-01048
(DC NM)
2018-06-15

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