Section Newsletters

Articles From Benjamin Haskin

The disappearance of the requirement that the Internal Revenue Service exhaust all reasonable collection efforts against the primary obligor By Benjamin Haskin Federal Taxation, September 2016 Recently, an increasing number of Memorandum Decisions in the United States Tax Court have summarily disposed of this requirement by stating that the existence and extent of transferee liability must be determined by state law, which often does not require the exhaustion of all reasonable collection efforts.

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