Separate notices for fraud-based and non-fraud tax determinations required, with adjudication and closure proceeding independently. Separate notices must be issued when a taxpayer has distinct subject matters requiring non-fraud and fraud-based tax determinations; officers must clearly delineate which matters fall under each category, and adjudication and closure shall operate independently at the notice level rather than by individual subject matter.
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.
Separate notices for fraud-based and non-fraud tax determinations required, with adjudication and closure proceeding independently.
Separate notices must be issued when a taxpayer has distinct subject matters requiring non-fraud and fraud-based tax determinations; officers must clearly delineate which matters fall under each category, and adjudication and closure shall operate independently at the notice level rather than by individual subject matter.
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