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.

November 2019

  • ATCL Conferencing Initiative Update
  • IRS Large Business & International Division Announces the Opening of the 2020 CAP Program for New Applicants for the First Time Since 2015
  • IRS Concludes Doctrine of Election Precludes Taxpayers from Relying on Hindsight to Make an Election on Amended Returns That Would Have Retroactively Reduced the Taxpayer’s Tax Liability
  • Divided Sixth Circuit Holds that the Anti-Injunction Act Bars Pre-Enforcement Challenge to Reporting Requirement Enforced by a Penalty that is Statutorily Defined as a Tax
  • Tax Court Holds that Copies of Return Not Filed in Service Center Did Not Begin the Running of the Period of Limitations on Assessment
  • District Court Rules Factual Issues Be Resolved to Determine Whether Taxpayer Was Subject to Penalty Under Section 6721 for Intentional Disregard
  • The Federal Circuit Applies the Codified Economic Substance Doctrine to Disregard Purported Payments Made to Claim Alternative Fuel Tax Credits and Upholds the Imposition of Penalties
November 2019

Archive

September 2019
Select Provisions of Interest in the Taxpayer First Act

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)

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