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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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November 2015

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November 2015

  • Tax Court Invalidates Transfer Pricing Regulations, Finding That They Did Not Satisfy the Reasoned Decisionmaking Standard under “State Farm”
  • Applying “Chevron,” Tax Court Upholds Validity of Section 911 Regulations Specifying the Requirements for Making an Election to Exclude Foreign Earned Income
  • Tax Court Upholds a TEFRA Partnership’s Statute Extension despite the Lack of an Authorized Signature, Based on the Signatory’s Apparent Authority
  • The Tax Court Denies a Taxpayer’s Motion to Dismiss Premised upon IRS’s Failure to Follow TEFRA Procedures
  • The Tax Court Concludes that Taxpayer’s Petition is Timely Because the Official Closing of the Tax Court Due to a Snowstorm was a Legal Holiday for Purposes of IRC § 7503


September 2015
The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely

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

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

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