Lawrence (Larry) A. Sannicandro was quoted in a recent Tax Notes article entitled “There May Be a Few Ways to Improve Tax Court Limited Appearances,” published on February 3, 2021. Sannicandro advocates for issue-based representation in proceedings before the United States Court to allow the court to more easily hear important procedural tax issues.
The article notes:
“Lawrence Sannicandro of Kostelanetz & Fink LLP said that issue-specific representations could
help the Tax Court evaluate legal questions that often arise for pro se petitioners, like collection
due process overpayment refund jurisdiction. He already participated in the litigation that
revolutionized courts’ approach to the IRS penalty approval process.
Sannicandro said another change that could make things easier for practitioners seeking to help
unrepresented petitioners would be to formalize the notice of completion mentioned in the
court’s most recent FAQ. Hopefully, he noted, the Tax Court will create specific procedures for
notices of completion that end limited appearances.
Formalizing the notice of completion would also help make subject-specific limited appearances
more appealing, to the benefit of the petitioners, the IRS, and the court, according to
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