FEDERAL TAX
PRACTICE AND
PROCEDURE
Leandra Lederman, Esq.
General Editor and Contributing Author
Ms. Lederman is the William W. Oliver Professor of Tax Law and Director of the Tax
Program at the Maurer School ofLaw, Indiana University in Bloomington, Indiana.
Ann Murphy, Esq.
Contributing and Update Author
Ms. Murphy is an Associate Professor of Law at Gonzaga University School of Law
in Spokane, Washington.
2010
Filed Through:
RELEASE NO.8 April 2010
.~ LexisNexis
e
CHAPTER 12
Judicial and Statutory
Doctrines that Avoid
Limitations Periods*
SYNOPSIS
§ 12.01 Judicial Doctrines
[1]
[2]
[3]
Judicial Doctrines to Ameliorate Inequity
Equitable Estoppel
[a] Traditional Doctrine
[b] Duty of Consistency
Equitable Recoupment
§ 12.02 Statutory Mitigation Provisions-IRC Sections 1311-1314
[1]
[2]
[3]
[4]
[5]
[6]
Overview of Statutory Mitigation Provisions
Qualified Determination
[a] Court Decisions
[b] Closing Agreements
[c] Final Decision on Claim for Refund
[d] Special Agreement
Inconsistent Positions
Qualified Inconsistent Treatment
[a] Duplication of Income
[b] Duplication of Deduction
[c] Duplication of Exclusion
[d] Dnplication of Disallowed Deduction
[e] Estates and Trusts
[f] AffIliated Corporations
[g] Basis of Property
Closed Year
Related Taxpayers
·Written by Bryan Camp, Associate Professor of Law, Texas Tech University School of Law.
12-1
(ReI.1-3103 Pub.l253)