tax proceedings

Sellers of shelters are obligated to defend their clients in tax proceedings, which typically go on for years.

A new wrinkle in those tax proceedings is the rise of speculators willing to buy properties threatened by city action.

Further, Mr. Biderman said that civil tax proceedings are pending that involve "a substantial amount."

At least four other states - New Jersey, Oregon, Ohio and Michigan - have similar small claims tax proceedings.

Unlike the attorney-client privilege, the FATP privilege does not apply in criminal matters, and does not apply in state tax proceedings.

Senator Pryor has introduced legislation, called the Taxpayer's Bill of Rights, that would generally shift the burden of proof in administrative and civil court tax proceedings from the taxpayer to the I.R.S.