In a showdown worthy of the O.K. Corral, the Tax Committee of the Court of Federal Claims Bar Association presents a brown bag program on the split between the IRS and taxpayers, which has been echoed in two recent conflicting decisions by the Court of Federal Claims. In Grapevine Imports, Ltd. V. United States, 77 Fed. Cl. 505 (2007) (Allegra, J.) and Salman Ranch Ltd. V. United States, 79 Fed. Cl. 189 (2007) (Miller J.), the Court reached opposite conclusions about when the IRS has six years, instead of three years, to assess additional taxes. Raising the stakes, the Federal Circuit has now accepted interlocutory appeal of the Salman Ranch decision.
Todd Welty of Meadows, Collier, Reed, Cousins & Blau, LLP, and Grover Hartt, III of the United States Department of Justice, (both riding in from Dallas, Texas), will go head-to-head in a no-holds-barred match on this issue.
Come watch the fireworks at High Noon on Monday, April 21, 2008, at the offices of Morgan, Lewis & Bockius, 1111 Pennsylvania Ave, N.W., Washington, D.C. Lunch will be provided gratis!