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Essay Multiple Choice

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All Jurisprudence based

0 tracked cards Commercial and Taxation Laws

A criminal tax case includes the government’s corresponding recovery of unpaid taxes. The accused argues that this automatically counts as the taxpayer’s own appeal against an FDDA, so no separate assessment-review steps can matter. What does Mendez explain?

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The deemed-instituted civil recovery concerns taxes relative to the criminal case; it is not automatically the taxpayer’s assessment appeal The taxpayer may disregard all appeal periods The government’s civil recovery and the taxpayer’s assessment appeal are always the same proceeding An FDDA can never be reviewed

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