Prima facie disallowance: limits tax deductions to substantiated, statutorily bounded, or not patently admissible claims under procedural controls. Prima facie disallowance is limited to claims that are (i) incorrect on the face of accompanying return information, (ii) unsupported by statutorily required documents filed with the return, (iii) in excess of explicit statutory limits where relevant data appears in the return, and (iv) patently inadmissible in law with no two opinions possible. No other prima facie disallowance may be made without the Commissioner's prior approval; subsequently furnished evidence may be considered by rectification as permitted by existing Board instructions. The procedure applies to returns pending processing on the circular's date.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Prima facie disallowance: limits tax deductions to substantiated, statutorily bounded, or not patently admissible claims under procedural controls.
Prima facie disallowance is limited to claims that are (i) incorrect on the face of accompanying return information, (ii) unsupported by statutorily required documents filed with the return, (iii) in excess of explicit statutory limits where relevant data appears in the return, and (iv) patently inadmissible in law with no two opinions possible. No other prima facie disallowance may be made without the Commissioner's prior approval; subsequently furnished evidence may be considered by rectification as permitted by existing Board instructions. The procedure applies to returns pending processing on the circular's date.
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