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Substantial Compliance Reporting Taxable Gift Sufficient to Start SoL
The Court ruled that a disclosure package submitted to IRS adequately disclosed transfer of company and related foreign accounts.
United states
Ronald schlapfer
Court ruling
Tax court
Disclosure program
Revenue service
Company on aug
Offshore voluntary disclosure program
Offshore entity statement
Internal revenue service
Revenue code section
Under treasury regulations section
Adequate disclosure regulation
Swiss cheese
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