IRS Insights

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.

September 2019

  • Select Provisions of Interest in the Taxpayer First Act
  • IRS Issues Penalty Relief to Partnerships and S Corporations that Relied on Proposed GILTI Regulations in Issuing Schedules K-1 to Partners
  • Revenue Procedure 2019-32 Provides a Six-Month Extension for Eligible BBA Partnerships to File a Superseding Form 1065 and Issue Corrected Schedules K-1
  • LB&I Issues Memorandum Regarding Timeframes for Cases to be Sent to Appeals
  • IRS Ends Moratorium on Opening New Cost Sharing Arrangement Stock-Based Compensation Examinations After the Ninth Circuit’s Decision in <i>Altera</i>
  • District Court Holds that an Individual Taxpayer Cannot Establish Reasonable Cause by Showing Reliance on a Tax Return Preparer to E-File a Tax Return
  • Court Declines to Dismiss a Taxpayer’s Equitable Estoppel Claim in <i>Fitzgerald Truck Parts & Sales v. United States</i>
  • DC Circuit Holds that the 30-Day Period for Petitioning the Tax Court Under Section 7623(b)(4) is Non-jurisdictional and Subject to Equitable Tolling
September 2019

Archive

July 2019
The Ninth Circuit Reverses the Tax Court in Altera

May 2019
Tax Court rules on proper process for Taxpayer to change their “Last Known Address” with the IRS

March 2019
Haynes v. United States: Can Reliance on a Return Preparer to E-File a Tax Return Establish Reasonable Cause?

January 2019
US Court of Appeals rules that taxpayer and its subsidiary foreign sales corporation are not the same taxpayer – Interest netting rules of Section 6621(d)

November 2018
Informal Refund Claims – Birger Engineering

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