Last week I attended the Treasures in the Attic-Tried and True Legal Principles in SALT session at the Paul J. Hartman State and Local Tax Forum presented by Janette Lohman and Brian Kirkell. I found the session very interesting and wondered if all state tax practitioners really know or understand how to use the legal principles that were discussed. Here is a list of the principles that were mentioned and can be used to defend your company or client.
- Manifest Injustice
- Equitable Estoppel
- Statute of Limitations
- Equitable Tolling
- Equitable Recoupment
- Collateral Estoppel
- Statutory Rules of Construction (Canons of Construction)
- Burden of Proof
- Regulations Cannot Expand the Reach of a Statute
- Retroactive Changes
- Doctrine of Consistency
- Laches
- Conformity