Representation
When Is a Return Considered Filed?
In Seaview Trading, LLC v. Commissioner,i a three-judge panel of the Ninth Circuit Court heard an appeal from the Tax Court, which tasked the court with deciding when a return ... Josh Youngblood, EA
Nov/Dec 2022,
Representation,
return,
Tax Court,
partnership,
Form 1065,
Ninth Circuit,
§7502,
Seaview,
Beard test,
statute of limitations,
assessments,
FPAA,
final partnership administrative adjustment,
Reg. §1.6031(a)-1(e)(1),
§1.6031(a)- 1(e),
§6229(a)