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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- Repairs vs. capitalization change in accounting method designated as LMSB Tier I Issue
- Partners’ outside basis and penalties related to its overstatement are affected items, appropriately determined at partner level
- Tax Controversy Updates
– Taxpayers to be notified of employment tax audits
– The IRS return preparer review report - Recent Guidance
– Announcement 2010-9: Uncertain tax positions – policy of restraint
– Treasury releases guidance, offers relief, for FBAR filing
– IRS updates adequate disclosure guidance
January 2010
Reliance on preparer was not reasonable, accuracy-related penalty upheld
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