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Are Alleged Alter Egos, Successors In Interest and/or Transferees Entitled to their Own CDP Rights?
February 27, 2018
Original appeared in Procedurally Taxing
Introduction
This blog post is the first in a short series of blog posts addressing the question of whether the IRS has been violating the Collection Due Process (“CDP”) procedures since they became effective in January of 1999 by refusing to extend CPD rights to alleged alter egos, successors in interest and/or transferees of the person/entity who/which incurred the tax, i.e., the original “taxpayer,” where no separate assessment has been made against the alleged alter ego, successor in interest and/or transferee.
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