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

September 2017

  • Federal Circuit Affirms FPAA Tolled Statute for Partnership when Losses were “Attributable To” Another Partnership
  • IRS Grants Relief for Partnerships Filing Returns or Extension Requests by the Due Date in Effect before the Enactment of the Surface Transportation Act
  • The Tax Court and the Court of Appeals for the Second Circuit Reach Contrary Conclusions as to the Section 6751(b)(1) Written-Approval Requirement for Sustaining an Accuracy-Related Penalty
  • IRS Issues Revised Guidance on Key Officer and Executive Tax Return Compliance Checks
  • IRS Releases FAQs on Appeals Team Cases Conferencing Initiative
September 2017


July 2017
Tax Court Holds that Certain Tax Return Information May Be Disclosed to an Employer Asserting a Defense to Withholding Tax

May 2017
US Tax Court sides with Amazon in intangibles transfer case

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

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