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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Recent editions appear below; for older issues, please email a request to

September 2015

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September 2015

  • The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely
  • The Court of Federal Claims Denies Refund Claim Based Upon Impermissible Change in Accounting Method
  • The Federal Circuit Court Refuses to Extend the Assessment Statute of Limitations Based on Third-Party Fraud
  • IRS Identifies Two New Reportable Transactions: Basket Option Contracts and Basket Contracts
  • The IRS Issues Final Regulations under Section 6402 for Filing a Claim for Credit or Refund


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

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

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