Judge Saylor also pointed out that applying the permissive approach allows for inconsistent treatment of the parties: requiring the plaintiff to seek leave but permitting the defendant to
amend freely.
As in Response #4 to question #1 above, if the amount were significant and there were intervening years, we would
amend the returns.
amends its laws or agrees to a provision in an income tax treaty with another country to allow tax-sparing credits, the parties with promptly
amend the convention to include a tax-sparing credit provision.
Plan sponsors who do not timely
amend their plans face potential loss of the plan's tax-qualified status, which may result in significant tax penalties.
In general, taxpayers have three years to
amend from the date of the original filing of their tax return (i.
Taxpayers may normally
amend a general claim any time before the Service acts on the refund claim (Factors & Finance Co.
