Learn about filing a lawsuit to challenge a Final Partnership Adjustment.
A petition for readjustment may be filed in a district court of the United States or the Court of Federal Claims only if the partnership filing the petition deposits with the IRS, on or before the date the petition is filed, the Imputed Underpayment Amount if the Partnership Adjustment was made as provided by the FPA. This white paper reviews what happens if there is more than one Imputed Underpayment reflected in the FPA and discusses the three time periods when dealing with the statute of limitations for Section 6235.
Agenda
Faculty
Charles D. Pulman
Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
- Tax partner with the Dallas law firm of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
- Practice focuses primarily on federal tax planning and compliance with extensive experience representing taxpayers under IRS audit and the resulting administrative and judicial proceedings
- Extensive experience representing entities taxed as partnerships and their partners
- Represents clients on tax matters throughout the United States
- Board certified in tax law by the Texas Board of Legal Specialization; he is also a Certified Public Accountant
- Writes and speaks extensively on tax related topics and has written and spoken on several occasions with regard to the new IRS audit regime affecting partnerships
- Recognized by his peers as a Texas Super Lawyer and recognized as one of the Best Lawyers in Dallas by D magazine
- LL.M. degree in taxation, New York University
- Can be contacted at 214-749-2447 or [email protected]
Mary E. Wood
Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
- Partner with the law firm Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
- Practice concentrates on resolving federal and state tax controversies, and white collar crime such as securities, tax and bank fraud
- Represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation in the United States Tax Courts, Federal District Courts and United States Court of Federal Claims; she also represents taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies
- Represents individuals and entities in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, noncompete violations, business torts, and other commercial disputes
- Texas Rising Stars, as published in Texas Monthly and in Texas Super Lawyers - Rising Stars Edition and on the web at superlawyers.com, Tax-2013-2019; Best Lawyers Under 40, D Magazine, 2017
- J.D. degree, with honors, University of Texas School of Law; B.B.A. degree in accounting, Texas A&M University
- Can be contacted at 214-744-3700 or [email protected]
All of your training, right here at Lorman.
Pay once and get a full year of unlimited training in any format, any time!
- Live Webinars
- OnDemand Webinars
- MP3 Downloads
- Course Manuals
- Audio Recordings*
- Executive Reports
- White Papers and Articles
- Sponsored Live Webinars
Additional benefits include:
- State Specific Credit Tracker
- Members Only Newsletter
- All-Access Pass Course Concierge
* For audio recordings you only pay shipping
Questions? Call 877-296-2169 to speak with a real person.
Thank You!
Download White PaperMore Program Information
Access to all training products $699/year
Unlimited Lorman Training
With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!
Easy Registrations
Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.
Invest in Yourself
You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.
