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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- Tax Controversy Updates
- IRS Chief Counsel Memorandum: Restricted Consent Agreements Extend Refund Statute Only for Items Identified in Consent
- Ninth Circuit Affirms Denial of Reasonable Cause Relief Where Taxpayer Relied on Advisor to Determine Due Date of Tax Return
- Tax Court Reverses Position on Applicability of Gross Valuation Misstatement Penalty Where Taxpayer Concedes Deduction on Unrelated Ground
- Tax Court Dismisses Petition Filed In Response to Invalid FPAA
- IRS Chief Counsel Memorandum: Penalties under IRC §§ 6721 and 6722 are Divisible for Purposes of Establishing Refund Jurisdiction
March 2013
Tax Controversy Updates: Government and Taxpayers Petition the U.S. Supreme Court to Resolve the Circuit Split on the Application of the Valuation Misstatement Penalty
January 2013
Tax Controversy Updates: FinCEN Notice 2012-2: FBAR Filings Extension for Certain Individuals With Signature Authority
November 2012
Tax Controversy Updates: Treasury Inspector General for Tax Administration Issues Report on Consistency of Penalty Abatement Procedures
September 2012
Tax Controversy Updates: IRS Announces Tiered Issue Process to be replaced by Issue Management Network
July 2012
Tax Controversy Updates: U.S. Court of Appeals Holds Gross Valuation Penalty Not Applicable When Deduction is Disallowed on Grounds Unrelated to Valuation
