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Laura Gavioli

About Laura Gavioli

Laura L. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, Laura is known for achieving practical, client-driven goals when defending against IRS inquiries.

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When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide

November 1, 2021 By Laura Gavioli and George Abney

Our Federal Tax Group investigates why the U.S. Supreme Court may use a Tax Court case to decide whether a statutory deadline is set in stone or if a court can permit an untimely suit to proceed through equitable tolling. The Tax Court ruled that a statutory deadline is jurisdictional; Eighth Circuit agreesTaxpayer access to the Tax Court is at stakeThe COVID-19 pandemic – and its attendant delays – has thrown the issue into the spotlight Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Equitable tolling, IRS, Taxpayers, U.S. Tax Court

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

May 24, 2021 By George Abney, Laura Gavioli and Eli McCrain

Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action. CIS Services v. IRS narrows the reach of the Anti-Injunction ActThree features of Notice 2016-66 helped the Court overturn lower courts’ rulings in favor of the IRSThe IRS’s rule-making process now open to more Administrative Procedure Act challenges Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Administrative Procedure Act, AIA, Anti-Injunction Act, CIS Services, IRS, Notice 2016-66, SCOTUS, Supreme Court

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