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13 J. Tax Prac. & Proc. 1 (2011-2012)

handle is hein.journals/jtaxpp13 and id is 1 raw text is: r

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Vol. 13, No. 1 February-March 2011
Contents

COLUMNS

5

Collection
By Carol M. Luttati                                                7
IRS Watch
By Kathy PetronchakJohn Keenan andfim McNiff                     9
Guest Column
By Frances D. Sheehy                                            13

ARTICLES

Challenging IRS Regulations: The Supreme
By Bruce Givner and Ken Barish

Court's Mayo

Decision 15

The Last, Best Chance to Disclose Foreign Financial Accounts
and Assets-The 2011 Offshore Voluntary Disclosure Program
and Beyond!
By Charles P Rettig and Kathryn Keneally                      21
The Meaning of Residence for FBAR Purposes
By Michael Karlin                                             37

Examination
By Harvey Coustan

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