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.
- US Tax Court sides with Amazon in intangibles transfer case
- District Court Holds that Taxpayer Must File Subsequent Refund Claims In Order to Be Entitled to Amounts Collected By the IRS While Refund Suit Is Pending
- Court of Appeals Affirms Tax Court Holding that a Notice of Deficiency Is Not Subject to the APA
- IRS Office of Chief Counsel Highlights Requirement for IRS to Determine the Value of Each Property Individually to Calculate Accuracy-Related Valuation Misstatement Penalties under IRC Section 6662
The Sixth Circuit Court of Appeals Limits IRS’ Use of Substance over Form Doctrine
The Federal Circuit Court of Appeals Holds Tax Shelter Penalties for Failure to Register Are Not Divisible
IRS Compliance Assurance Process Program under Review
Proposed and Temporary Regulations for Electing Into the BBA Partnership Audit Regime Issued
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