IRS Insights


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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September 2016

September 2016

  • Proposed and Temporary Regulations for Electing Into the BBA Partnership Audit Regime Issued
  • Tax Court Examines Taxpayers’ Discovery Responses Generated Using Predictive Coding
  • Federal Circuit Examines When Separate Entities Are Considered to Be the Same Taxpayer for Interest-Netting Purposes
  • The Tax Court, Applying the Federal Rules of Civil Procedure, Concluded that Taxpayer’s Petition is Timely because it was Filed on the First Day that the Court was Accessible after a Weather-Related Closure
  • IRS Issues Legal Memorandum Discussing Applicability of Penalties under IRC § 6721 Where Withholding Agent Files Form 1042-S Reporting Incorrect TIN


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

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

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