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Searching Content indexed under Income Tax by Robin Greenhouse ordered by Published Date Descending.
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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
2
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
3
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
4
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
5
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
6
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
7
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
8
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
9
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
10
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
11
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
12
IRS Addresses Whether Publisher Is "Producer" Under §199
In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an "electronic" version of books that were "printed" by a third party did not constitute qualifying manufacture, production, growth or extraction activities for purposes of the §199 deduction.
United States
6 Apr 2013
13
April 15th Deadline For Filing FICA Refunds For Severance Pay
Severance pay due to an involuntary separation from employment resulting from a reduction in force, plant shutdown or similar condition may be exempt from FICA taxes.
United States
23 Jan 2013
14
Tax Court Makes Significant Amendments To Privilege And Discovery Rules
Taxpayers under audit should be aware of significant amendments to the U.S. Tax Court's rules on work product protection and the discoverability of draft expert witness reports and certain communications between counsel and experts.
United States
15 Aug 2012
15
Section 263A Regulation Falters Under the Chevron Two-Step and Administrative Procedure Act
It’s not often that U.S. Treasury Department Regulations are invalidated under the Chevron two-step analysis and the Administrative Procedure Act.
United States
13 Jun 2012
16
IRS Releases Draft Schedule and Instructions for Reporting Uncertain Tax Positions
Announcement 2010-30 provides additional details and clarifications regarding the type of information taxpayers will have to provide, but assumes that the IRS has the authority to require a taxpayer to provide information on uncertain tax positions.
United States
5 May 2010
17
IRS Concedes That Medical Residents Qualify For Student Exception From FICA Taxes For Taxable Quarters Ending Prior To April 1, 2005
Each teaching hospital should assess the state of its administrative refund claims in order to be prepared for a contact from the IRS.
United States
24 Mar 2010
18
3-2 En Banc First Circuit Decision in Textron Rules That Tax Accrual Workpapers Are Not Protected Work Product
The U.S. Supreme Court may be inclined to grant certiorari to resolve the split in the circuits and address the broad ramifications of the First Circuit’s decision, including state and local implications.
United States
13 Sep 2009
19
3-2 En Banc First Circuit Decision In Textron Rules That Tax Accrual Workpapers Are Not Protected Work Product
The U.S. Supreme Court may be inclined to grant certiorari to resolve the split in the circuits and address the broad ramifications of the First Circuit’s decision, including state and local implications.
United States
20 Aug 2009
20
Textron Protects Tax Accrual Workpapers From IRS Summons
Court’s decision addresses scope of work product doctrine and waiver of work product protection.
United States
25 Sep 2007
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