Advance ruling voidability: rulings obtained by fraud may be treated as never made, restoring ordinary tax law application. The Authority may declare an advance ruling void ab initio if obtained by fraud or misrepresentation; upon such declaration the Code applies to the ... Summary
Advance ruling voidability: rulings obtained by fraud may be treated as never made, restoring ordinary tax law application.
The Authority may declare an advance ruling void ab initio if obtained by fraud or misrepresentation; upon such declaration the Code applies to the applicant as if the ruling had never been made, excluding the period between the ruling's date and the date of the Authority's order, and a copy of the order is sent to the applicant and the Commissioner.
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