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IRS Insights - July 2009

Publish date:

Deloitte ImageWelcome to the bimonthly publication, IRS Insights, produced by the Deloitte Tax Controversy Services group to keep our clients abreast of current issues related to the Internal Revenue Service.

In this month's issue:

  • IRC Section 7525 federally authorized tax practitioner privilege upheld for meeting minutes and handwritten notes
  • Transaction documents discoverable pursuant to tax shelter exception to IRC Section 7525 federally authorized tax practitioner privilege
  • Tax Controversy Updates
    – Amended return filed by individual partners does not qualify as an administrative adjustment request
    – Joint committee review of refund claims
  • Recent Guidance
    IRS clarified requirement for filing FBAR form due June 30, 2009
    The IRS published additional FAQs for the voluntary FBAR disclosure program

See attached file for details.

Visit the IRS Insights Archive for issues from the past year.

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    IRC Section 7525 federally authorized tax practitioner privilege upheld for meeting minutes and handwritten notes

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