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12 J. Tax Prac. & Proc. 1 (2010-2011)

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1o2, No. I February-March 2010
COLUMNS
Examination
By Kevin E. Thorn
Collection
By Carol M. Lutatti
IRS Watch
By Kathy PetronchakJohn Keenan and Julia Lagun
Practice
By Charles P Rettig and Kathryn Keneally
ARTICLES
Filing Positions, Tax Practitioners and Disclosure
By Mark Reid
Who Owns the Client's File?
By LarryJones, Kory Ryan andlenna Braisted
No Returns, No Problem: Tax Court Rules in Case of First
Impression That IRS Must Consider Economic Hardship
in Pre-Levy CDP Cases
By Hale E. Sheppard
S. G. Smith: Taxpayers Must Pay the Listed Transaction Penalty
and Sue for a Refund
By Bruce Givner and Ken Barrish
Sampling and the IRS
By Howard M. Weinman
Proposed Regulations Address Reporting of Credit and
Debit Card Transactions
By Steven Friedman

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