A closer look.
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.
- Tax Court Holds that the Two-Year Lookback Period of Section 6511(b)(2) Bars an Individual From Receiving a Refund Even Though IRS Agreed the Individual Overpaid His Taxes
- Seventh Circuit Affirms Reformation of Faulty Assessment Statute of Limitations Extensions
- Rev. Proc. 2016-30 Modifies Pre-Filing Agreement Procedures including Significantly Increasing User Fees
- Tax Court Holds that Administrative Procedure Act Doesn’t Apply to Deficiency Cases
- A Taxpayer Invoking the Substance-Over-Form Doctrine to Reform its Own Contract is Prevented by the <i>Danielson</i> Rule
Rev. Proc. 2016-22 Clarifies the Practices for the Administrative Appeals Process in Cases Docketed in the Tax Court
LB&I Issues Updated Examination Process
Changes Made to Partnership Audits and Adjustments
Tax Court Invalidates Transfer Pricing Regulations, Finding That They Did Not Satisfy the Reasoned Decisionmaking Standard under “State Farm”
The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely
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