Proof of Facts in SALT Cases: Do’s and Don’ts



Peter Faber wrote this bylined article emphasizing the care practitioners should take to establish the facts of their tax controversy case. “I have seen all too many situations in which taxpayer advocates have not treated the proof of facts carefully or systematically,” Mr. Faber wrote. “They have not realized that they have the burden of proof and that department officials will not be satisfied with simply receiving the unsupported statements of an accountant or a lawyer as to what the facts were.”