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11 J. Tax Prac. & Proc. 1 (2009-2010)

handle is hein.journals/jtaxpp11 and id is 1 raw text is: CCH Journals and Newsletters ' Email Alert for the Current Issue Sign Up Here... CCHGroup.com/Emaitl/Journals Vol. 11, No. 1 February-March 2009 Contents COLUMNS Examination By Harvey Coustan 5 Collection By Carol M. Lutatti 7 IRS Watch ByJohn Keenan, Kathy Petronchak andjulia Lagun L/ Practice By Charles P Rettig and Kathryn Keneally Guest Column ByJonathan Barry Forman 2 1 ARTICLES Recent Developments and Decisions from the IRS Office of Professional Responsibility By Laura L. Gavioli 23 Two More Blows to Foreign Account Holders: Tax Court Lacks FBAR Jurisdiction and Bankruptcy Offers No Relief from FBAR Penalties By Hale E. Sheppard I Does the Tax Court's Use of Its Golen Rule in Unappealable Small Tax Cases Hurt the Poor? By Carlton M. Smith 3 Top Tax Practice and Procedure Blunders That Can and Should Be Avoided By Michael G. Goller and Harvey Coustan 39 P Journal orf'