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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July 2015

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July 2015

  • A District Court Holds IRS’s Assessment of a Reportable Transaction Penalty was Untimely under Section 6501(c)(10) as IRS Had Been Furnished the Required Information More Than One Year before Assessment
  • Recent Cases Discussing Privilege: The Tax Court Finds No Attorney-Client Privilege for Emails Listed in Privilege Log, While a District Court Concludes that Both the Attorney-Client Privilege and the Work Product Doctrine Protect Two Memoranda
  • IRS Releases Guidance on FBAR Penalties Containing Procedures for the Determination, Calculation, and Assessment of FBAR Penalties
  • Tax Court Concludes that Taxpayer Did Not Satisfy the Requirements for Automatic Consent but Nonetheless Changed its Method of Accounting and Could Not Revert to the Previous Method of Accounting by Filing Amended Returns


May 2015
The Tax Court Holds that Raising the Reasonable Cause and Good Faith Defense to the Accuracy-Related Penalty May Cause a Waiver of Privilege

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

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

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