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

January 2017

  • The Federal Circuit Court of Appeals Holds Tax Shelter Penalties for Failure to Register Are Not Divisible
  • District Court Holds that Taxpayer’s Administrative Refund Claim was Deficient for Failing to Include Required Documents
  • IRS Notice Identifies Certain “Micro-Captive” Transactions as Transactions of Interest
  • Court of Federal Claims Examines <i>Skidmore</i> Deference in Two Recent Cases
January 2017


November 2016
IRS Compliance Assurance Process Program under Review

September 2016
Proposed and Temporary Regulations for Electing Into the BBA Partnership Audit Regime Issued

July 2016
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

May 2016
Rev. Proc. 2016-22 Clarifies the Practices for the Administrative Appeals Process in Cases Docketed in the Tax Court

March 2016
LB&I Issues Updated Examination Process

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