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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May 2017

  • 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
May 2017


March 2017
The Sixth Circuit Court of Appeals Limits IRS’ Use of Substance over Form Doctrine

January 2017
The Federal Circuit Court of Appeals Holds Tax Shelter Penalties for Failure to Register Are Not Divisible

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

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