IRS Insights Archive |
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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- Subject Matter Jurisdiction in Federal Claims Court Lost When Petition for Redetermination was Filed in Tax Court
- According to Chief Counsel Reexamination In Connection With Refund Was Not Precluded Under Code Section 7605
- Tax Controversy Updates
- Revised Form 2848, Power of Attorney and Declaration of Representative
- Electronic Data Files - Recent Guidance
- Foreign Financial Asset Reporting
- Fact Sheet for U.S. Citizens Living Abroad
November 2011
Amended return filed after promoter was notified of investigation was not a qualified amended return and did not protect taxpayer from penalties
September 2011
Where taxpayer failed to file information returns statute of limitations on assessment remained open
July 2011
Court found no reasonable cause for income omission where taxpayer relied on return preparer
May 2011
Taxpayer with novel issue at the time of filing granted reasonable cause relief
March 2011
Six-Year Statute of Limitations Triggered by Overstatement of Basis Resulting in Gross Omission from Income Outside of the Trade-or-Business Context
