Searching Content by Robin Greenhouse ordered by Published Date Descending.
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The IRS Attacks Taxpayers' Section 199 (Computer Software) Deductions
Taxpayers' section 199 computer software deductions are under attack! The issue is being coordinated within the IRS, and at Exam and Appeals taxpayers are running into a brick wall.
United States
7 Nov 2017
UTP Filings Continue To Rise
The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP filings, showing that there were 6,320 uncertain tax positions reported in 2014.
United States
18 Oct 2016
Deference Denied To IRS Notice Issued Post-Litigation
Sometimes a loss in a discovery battle is really a win. That is certainly the outcome in Sunoco, Inc. v. United States, 2016 WL 334578 (Fed. Cl., No. 1:15-cv-00587, 10/6/16).
United States
17 Oct 2016
IRS Updates Rules Regarding Appeals Conferences
The Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016:
United States
26 Sep 2016
IRS Wages ‘Campaigns' against Taxpayers
Late last year, the Internal Revenue Service's (IRS's) Large Business and International (LB&I) division announced that it would restructure its organization.
United States
29 Jun 2016
Tax Court Rules In Favor Of Medtronic In Transfer Pricing Case Against IRS
Although the Tax Court found the taxpayer's royalty rates established using the comparable uncontrolled transaction method to be unreasonable, the court undertook to determine the proper allocations itself...
United States
13 Jun 2016
Two Current Tax Controversies Utilize ‘Quick Peek' Agreements To Resolve Privilege Disputes
Due to the enormous amount of electronic data stored by companies in the modern era, discovery requests can involve millions of documents which need to be reviewed prior to being turned over to the opposing party.
United States
1 Jun 2016
Whose Intent To Evade Tax Is It?
On July 29, 2015, the Federal Circuit, rejecting the Tax Court's decision in Allen v. Commissioner, held in BASR Partnership v. United States, that section 6501(c)'s suspension of the three-year period of limitations for assessment for fraud or false returns applies only when the taxpayer — and not a third party — acts with the requisite "intent to evade tax."
United States
5 Aug 2015
When Is A Second Inspection Not A Second Inspection?
In order to ensure the proper determination of a tax liability, Congress "has endowed the IRS with expansive information-gathering authority."
United States
16 Apr 2015
Tax Court Extends Implied Waiver Of Privilege To Taxpayers’ State of Mind Penalty Defense
The U.S. Tax Court concludes in AD Investment 2000 Fund LLC v. Commissioner that a taxpayer’s assertion of a state of mind penalty defense waives the attorney-client privilege with respect to tax opinions provided to the taxpayer in advance of filing the taxpayer return, even if the taxpayer explicitly disclaims reliance on the tax opinions.
United States
28 Apr 2014
Supreme Court Grapples With Showing Required For Evidentiary Hearing Before Summons Enforcement
After hearing oral arguments in a case alleging the Internal Revenue Service issued summonses for an improper purpose, the Supreme Court of the United States is set to provide guidance on the type of evidence that a summoned party must show to entitle it to an evidentiary hearing before summons enforcement.
United States
25 Apr 2014
Choice Of Forum In Federal Excise Tax Refund Cases
Taxpayers seeking a refund of the Internal Revenue Service’s administrative decision to impose additional excise tax may petition either the U.S. district courts or the U.S. Court of Federal Claims.
United States
1 Apr 2014
Supreme Court Decides In Favor Of IRS In Quality Stores: FICA Generally Applies To Severance Payments
The Supreme Court of the United States has decided in favor of the Internal Revenue Service in United States v. Quality Stores, Inc., holding that severance payments made pursuant to plans that did not tie payments to the receipt of state unemployment insurance are subject to Federal Insurance Contributions Act (FICA) tax.
United States
26 Mar 2014
IRS Lacks Authority To Issue And Enforce Tax Return Preparer Regulations
On February 11, 2014, the U.S. Court of Appeals for the District of Columbia upheld the decision of the District Court for the District of Columbia, affirming that the Internal Revenue Service (IRS) lacked the authority to issue and enforce tax return preparer regulations it issued in 2011, and permanently enjoined the IRS from enforcing the regulations.
United States
22 Feb 2014
Deadline Looms For Quality Stores FICA Refund Claims For Severance Payments
The Supreme Court of the United States recently heard arguments in its review of the U.S. Court of Appeals for the Sixth Circuit's Quality Stores decision.
United States
15 Feb 2014
Supreme Court Downplays The Blue Book’s Interpretative Value
On December 3, 2013, the Supreme Court of the United States dismissed the applicability of the Blue Book, a commentary of recently passed tax laws prepared by the Joint Committee on Taxation, as little more than a law review article.
United States
12 Dec 2013
Court Of Federal Claims Rules Adviser Fraud Does Not Extend Three-Year Statute Of Limitations Period
The U.S. Court of Federal Claims recently held that third-party fraud committed on a partnership’s tax return did not extend the three-year statute of limitations period for assessment of income taxes, a decision that conflicts with U.S. Tax Court precedent.
United States
28 Oct 2013
U.S. Tax Court: 90 Days Is 90 Days, Shutdown Or Not
On October 1, 2013, the majority of the U.S. government shut down, including the U.S. Tax Court. Despite the shutdown, the statutory deadline for filing a petition in the Tax Court cannot be extended.
United States
14 Oct 2013
Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims
On September 9, 2013, the U.S. Court of Appeals for the Second Circuit held that the District Court had jurisdiction to hear the taxpayer’s case based on the taxpayer’s use of a protective refund claim.
United States
18 Sep 2013
IRS Denied Peek Behind The Curtain: District Court Protects Wells Fargo’s Tax Accrual Workpapers
In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege.
United States
13 Jun 2013
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