Searching Content indexed under Trials & Appeals & Compensation 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
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
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