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

May 2024

Here are some of the latest tax rulings in our May edition:

  • Court Rules Wrong Form Doesn’t Start IRS’s SOL
    • In Lagerkvist v. United States, a district court rejected a taxpayer’s argument that the IRS’s assessment statute of limitations began when she filed a Form 941 instead of Form 944.
  • Tax Court Invalidates Treasury Regulation to Find Petition Timely Filed
    • Recently, the Tax Court ruled that section 7508A(d) provides for an automatic, mandatory 60-day postponement period for qualified taxpayers to meet certain deadlines in the event of a declared federal disaster, even if the IRS has not exercised its postponement authority under section 7508(A)(a).
  • IRS Proposes Regulations Identifying Certain Charitable Remainder Annuity Trusts as Listed Transactions
    • In late March, the IRS published a notice of proposed rulemaking and issued proposed regulations identifying certain charitable remainder annuity trust (“CRAT”) transactions as “listed transactions.” The proposed regulations, published in the Federal Register on March 25, 2024, are meant to address concern over the use of CRATs and single premium immediate annuities to avoid the recognition of ordinary income and/or capital gains.
May 2024


March 2024
IRS indefinitely authorizes electronic signatures for select forms and documents

September 2023
Supreme Court to Hear Challenge to Section 965 transition tax

May 2023
Recent Tax Court decision holds Form 5471 penalties are not immediately assessable by the IRS

March 2023
IRS proposes regulations regarding taxpayer access to Appeals

November 2022
Failure-to-file penalties apply when certain forms are paper file

August 2022
Tax Court reiterates rule that each tax year stands on its own

June 2022
Taxpayer refund suit dismissed for inability to prove timely mailing of refund claim

February 2022
Ninth Circuit adopts primary purpose test for determining whether attorney-client privilege applies to dual-purpose communications

October 2021
The IRS issued Notice 2021-39, announcing transition relief for Schedules K-2 and K-3 filers for taxable years beginning in 2021.

July 2021
In Crandall v. Commissioner of Internal Revenue, the Tax Court addressed a question about the scope and effect of a closing agreement signed between the taxpayers and the IRS

April 2021
Court holds that Section 6676 erroneous refund penalty does not apply in Exxon Mobil Corp. v. United States

January 2021
Nonresident USVI taxpayer “filing” under Section 6501(a)

November 2020
Federal Claims Court Rules on Failure to Meet Reasonable Cause in Payroll Tax Obligations

September 2020
IRS Request Comments on Revenue Procedure 94-59

July 2020
CCA Memo on Meaning of “Attributable To” in 6511(d)(2)

May 2020
IRS issues Rev. Proc. 2020-23 to allow BBA partnerships to utilize relief provisions provided in the CARES Act

March 2020
Tax Court Tentatively Disallows Conservation Easement Deduction Due to Omitted Required Basis Information

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