IRS Insights


IRS Insights

IRS Insights, published by the Deloitte Tax LLP Tax Controversy Services group, provides a compact, reader-friendly perspective on the latest practices and procedures coming out of the Internal Revenue Service (IRS), as well as the potential impact of changes on taxpayers.

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March 2015

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March 2015

  • The Tax Court’s Recent Determination That a Taxpayer Did Not Meet the Three-Factor Test for Informal Refund Claims and a Review of Cases in Which Courts Have Treated a Refund Request Made on an Incorrect Form as an Informal Refund Claim
  • The Tax Court Reforms Faulty Assessment Statute of Limitations Extensions
  • IRS Issues Email Advice Specifying the Application of the <i>Ex Parte</i> Rules to Docketed versus Non-Docketed Cases
  • The IRS Issued Rev. Proc. 2015-13, which Significantly Modifies the Procedures Applicable to Taxpayers under Examination Filing Accounting Method Changes


January 2015
The Court of Federal Claims Allows Interest Netting on Pre- and Post-Merger Underpayments and Overpayments

November 2014
IRS Memorandum Addresses the SB/SE Division’s Use of the New IDR Enforcement Process in Employment Tax Examinations

September 2014
IRS Memorandum Provides Implementation Guidance for Phase 2 of the AJAC Project

July 2014
District Court Concludes that Attorney-Client/Tax Practitioner Privileges and Work Product Doctrine Did Not Protect Tax Memorandum from Disclosure in Summons Enforcement Case

May 2014
IRS Provides for Automatic Determination Under Treas. Reg. § 1.1502-75(b) to Treat a Subsidiary that Failed to File a Form 1122 as Joining in the Making of a Consolidated Return by the Affiliated Group

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