TaxTMI 
TaxTMI 
For 2 different audits points, we wish to pay interest amount due to small amounts, where as in other case, due to interest amounts are high decided to contest. How dept. can litigate our two different stands in similar case?
Litigation - two different stands
02 May 2009 
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Differential litigation strategy allows paying minor interest liabilities while contesting major audit issues; legal questions decided on merits.
Taxpayers may deposit interest on minor audit points while contesting other significant points; the department cannot treat the taxpayer's mixed procedural choices as determinative. Each legal issue must be decided on its merits, and paying small liabilities for pragmatic reasons does not bar contesting separate legal grounds arising from the same audit. (AI Summary)
Taxpayers may deposit interest on minor audit points while contesting other significant points; the department cannot treat the taxpayer's mixed procedural choices as determinative. Each legal issue must be decided on its merits, and paying small liabilities for pragmatic reasons does not bar contesting separate legal grounds arising from the same audit. (AI Summary)