If you are willing and able to litigate
, you are likely to have many more IRS strategy options.
68) The Nash strategy is, in game-theoretic terms, a mixed strategy: Vitamin's best strategy is to litigate
if Supplement litigates
, and to settle early if Supplement settles early.
The third area of inquiry that should be explored in making the "to litigate
or not to litigate
" decision is whether the available data, in terms of potential exposure, is substantial enough that it will command the defendant's attention and warrant their willingness to discuss a resolution, as well as warrant the significant investment in terms of cost and utilization of resources that the insurance company is likely to have to make.
Daley, who has been following the residential cases where a stay based on unconstitutionality claims was stayed on the filing of a notice of appeal by the New York State Attorney's General's office, said "The law will give us a couple of good issues to litigate
between now and the end of the century.
6213), should allow it to continue to litigate
Tax Court or Court of Federal Claims) in which to litigate
a partnership tax controversy
Form 870 may be used in Appeals if the taxpayer wants to litigate
its case in Federal district court or the Court of Federal Claims.
The Service did not acquiesce in this decision, and intends to litigate
the issue in other circuits.
6601(e)(2) is important in determining whether interest charges have been properly computed, in deciding whether to litigate
or settle, and in choosing the best method of payment allocation when both tax and penalties have been assessed.