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

November 2022

Read about some of the latest tax rulings in our November edition of IRS Insights:

  • Failure-to-file penalties apply when certain forms are paper file
    • The IRS released a Chief Counsel memorandum regarding penalties when taxpayers paper file certain forms that are required to be filed electronically.      
  • DC Circuit affirms that a partnership that is profitable only after claiming tax incentives is bona fide
    • The DC Circut Court of Appeals recently rules that a partnership formed to conduct activity made profitable only by tax credits engaged in legitimate business activities for US federal income tax purposes.
  • Taxpayer cannot invalidate closing agreement
    • In Smith v. Commissioner,the Tax Court rejected the taxpayer's attempts to invalidate a closing agreement he entered into with the IRS.
  • Court allows IRS to assess interest after closing agreement
    • In Chesapeake Energy Corporation v. United States,2 a district court ruled that the IRS could assess interest for a tax year in which the IRS and taxpayer had entered into a closing agreement.


 1 Smith v. Commissioner, 159 T.C. No. 3 (2022).                                                                                 Chesapeake Energy Corporation v. United States, No. 5:20-cv-00934 (W.D. Okla. September 6, 2022).      


November 2022


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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