It’s Not Over Till It’s Over: Lessons from Crandall about Closing Agreements and Key Procedural Issues in Tax Disputes



To have success against the IRS, taxpayers must understand substantive tax law and procedure. Too many are clueless about the latter, which ultimately causes their downfall. This article analyzes a recent Tax Court case, Crandall v. Commissioner, using it as a springboard for learning important lessons about the effect of Closing Agreements with the IRS, unique steps in rectifying international tax issues, and procedural questions that often arise.


About Hale E. Sheppard

HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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