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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May 2015

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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
  • Tax Court Rejects Taxpayers’ Statute of Limitations Defense and Related Judicial and Equitable Estoppel Grounds for Summary Judgment and Concludes that the Duty of Consistency Doctrine is Not Applicable
  • The IRS Explains the Scope of the Statute of Limitations Extension under IRC § 6501(c)(8)
  • IRS Releases FY 2014 Statistics on Enforcement and Business Examinations, IRS Examination Staffing, and the IRS Budget, and the Commissioner Discusses the Impact of the FY 2015 Budget Cuts on the IRS and Taxpayers and Advocates for Increased Funding in the FY 2016 Budget
  • New IRS Audit Technique Guide


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

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

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