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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- First Circuit in Textron rejects taxpayer’s claim of work product protection for tax accrual workpapers in IRS examinations
- Partnership statute may extend partners’ assessment statute, but not shorten it
- Tax Controversy Updates
– Additional relief provided for foreign bank account reporting
– Listed transactions and transactions of interest
– IRS disaster relief for Kentucky storms and flooding victims - Recent Guidance
– Accuracy-related penalty upheld despite tax return preparer’s admitted mistake
– Lack of proper signature does not disqualify refund claim
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
November 2008
Deposit Required with Court of Federal Claims for All Affected Tax Years to Bring Action in TEFRA Case