IRS Insights Archive |
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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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- Taxpayer not liable for accuracy related penalty in Son of BOSS tax shelter case
- Overpayment was outside the “look-back” period, and refund claim was thus time barred
- Tax Controversy Updates
– Overstatement of basis does not trigger six year statute of limitations
– Temporary regulations define omission from gross income for purposes of statute of limitations - Recent Guidance
– IRS updates appeals mediation procedures
– IRS changes procedures for late entity classification elections
September 2009
First Circuit in Textron rejects taxpayer’s claim of work product protection for tax accrual workpapers in IRS examinations
July 2009
IRC Section 7525 federally authorized tax practitioner privilege upheld for meeting minutes and handwritten notes
May 2009
No settlement agreement due to lack of authorized signature and mutual assent
March 2009
Company’s tax accrual work papers protected by work product privilege
January 2009
Jurisdiction, once invoked, remains unimpaired