Sisters Could Not Raise New Arguments in Rule 155 Proceeding (Vento, TC)

Three sisters could not raise new arguments in a Rule 155 proceeding. Therefore, the court rejected their tax computations and adopted the IRS’s instead. Prior Opinion In a prior opinion, the court held that the sisters could not take foreign tax credits for their payments to the VIBIR because: they were not bona fide residents of the […]

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