IRS Insights Archive |
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Published
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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- Reliance on preparer was not reasonable, accuracy-related penalty upheld
- FPAA proposing adjustments “directly attributable” to flow-through items considered timely
- Tax controversy updates
– NOL carryback period extended
– Procedural guidance on the five-year NOL carryback - Recent guidance
– Coordination of docketed tax court cases involving a substantial omission of income resulting from an overstatement of basis
– Requests for return of excess deposits and related interest
November 2009
Taxpayer not liable for accuracy related penalty in Son of BOSS tax shelter case
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