IRS Insights

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IRS Insights

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.

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Recent editions appear below; for older issues, please email a request to ustaxnews@deloitte.com.

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July 2016

July 2016

  • 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

Archive

May 2016
Rev. Proc. 2016-22 Clarifies the Practices for the Administrative Appeals Process in Cases Docketed in the Tax Court

March 2016
LB&I Issues Updated Examination Process

January 2016
Changes Made to Partnership Audits and Adjustments

November 2015
Tax Court Invalidates Transfer Pricing Regulations, Finding That They Did Not Satisfy the Reasoned Decisionmaking Standard under “State Farm”

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

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