IRS Insights provides concise and accessible perspectives from Deloitte Tax LLP's Tax Controversy Services group. Featuring the latest practices and procedures coming out of the Internal Revenue Service (IRS) to help you stay informed and prepared on how these changes may impact taxpayers.
May 2026
Key highlights include updates that another circuit holds IRS can automatically assess section 6038(b) penalty, and Tax Court finds administrative error does not invalidate FPA. Additionally, TIGTA provides feedback on IRS partnership compliance initiatives, Tax Court applies economic substance doctrine to disallow partnership basis adjustment, as well as Tax Court cautions the rejection of IRS appeals conference precludes subsequent liability challenges.