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Perspectives
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.
March 2024
Here are some of the latest tax rulings in our March edition:
- IRS indefinitely authorizes electronic signatures for select forms and documents
- In October 2023, the Internal Revenue Service (IRS) announced it was updating its policy for signatures to indefinitely accept electronic or digital signatures (“e-signatures”) on certain forms and documents.
- Taxpayers cannot rely on advisors to file returns, even if e-filed
- A US Court of Appeals recently ruled taxpayers cannot defeat a “failure to file” penalty because they authorized their return preparer to electronically file their tax return. The United States Court of Appeals for the Eleventh Circuit ruled the bright-line rule applies to e-filed returns.
- A US Court of Appeals recently ruled taxpayers cannot defeat a “failure to file” penalty because they authorized their return preparer to electronically file their tax return. The United States Court of Appeals for the Eleventh Circuit ruled the bright-line rule applies to e-filed returns.
- IRS updates annual revenue procedures regarding adequate disclosure
- The IRS recently updated its revenue procedure that provides guidance on when taxpayers have adequately disclosed an item or position for purposes of reducing a substantial understatement subject to the section 6662 accuracy-related penalty.
- The IRS recently updated its revenue procedure that provides guidance on when taxpayers have adequately disclosed an item or position for purposes of reducing a substantial understatement subject to the section 6662 accuracy-related penalty.
- Tax Court rejects IRS arguments re whipsaw, duty of consistency, and doctrine of election
- The Tax Court recently ruled that a taxpayer could disavow its original characterization of certain transfers as debt and reclassify them as equity.
- The Tax Court recently ruled that a taxpayer could disavow its original characterization of certain transfers as debt and reclassify them as equity.
- IRS Notice 2024-19 provides penalty relief for failure to furnish Part IV of Form 8308 to transferors and transferees in section 751(a) exchanges by January 31, 2024
- IRS announced waiver of failure to pay penalties for certain returns for 2020 and 2021 tax years
March 2024
Archive
September 2023
Supreme Court to Hear Challenge to Section 965 transition tax
May 2023
Recent Tax Court decision holds Form 5471 penalties are not immediately assessable by the IRS
March 2023
IRS proposes regulations regarding taxpayer access to Appeals
November 2022
Failure-to-file penalties apply when certain forms are paper file
August 2022
Tax Court reiterates rule that each tax year stands on its own
June 2022
Taxpayer refund suit dismissed for inability to prove timely mailing of refund claim
February 2022
Ninth Circuit adopts primary purpose test for determining whether attorney-client privilege applies to dual-purpose communications
October 2021
The IRS issued Notice 2021-39, announcing transition relief for Schedules K-2 and K-3 filers for taxable years beginning in 2021.
July 2021
In Crandall v. Commissioner of Internal Revenue, the Tax Court addressed a question about the scope and effect of a closing agreement signed between the taxpayers and the IRS
April 2021
Court holds that Section 6676 erroneous refund penalty does not apply in Exxon Mobil Corp. v. United States
January 2021
Nonresident USVI taxpayer “filing” under Section 6501(a)
November 2020
Federal Claims Court Rules on Failure to Meet Reasonable Cause in Payroll Tax Obligations
September 2020
IRS Request Comments on Revenue Procedure 94-59
July 2020
CCA Memo on Meaning of “Attributable To” in 6511(d)(2)
May 2020
IRS issues Rev. Proc. 2020-23 to allow BBA partnerships to utilize relief provisions provided in the CARES Act
March 2020
Tax Court Tentatively Disallows Conservation Easement Deduction Due to Omitted Required Basis Information
