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

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.

In CIC Services v. Internal Revenue Service, the Supreme Court held in a unanimous opinion that a preenforcement challenge to enjoin an aspect of the IRS’s reportable transaction information reporting regime was not precluded by the Anti-Injunction Act.

In IQL v. Kingsbridge Technology, a District Court had to decide whether the doctrines of attorney-client privilege and work product doctrine protections apply to certain emails and tax preparation documents.

July 2021


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

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