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In addition to the discussion of the Tax Court's decision in Altera, this month's issue features articles regarding Notice 2015-47 "Basket Options" and Notice 2015-48 "Basket Contracts"...
In addition to the discussion of the Tax Court's decision
in Altera, this month's issue features articles
regarding Notice 2015-47 "Basket Options" and Notice
2015-48 "Basket Contracts", the Federal Circuit Court of
Appeals decision is BASR Partnership v. United
States that Section 6501(C)(1)'s suspension of the
three-year limitation applies only when the taxpayer acts with the
requisite intent to evade tax, a recent Circuit Court ruling that
upheld the application of the attorney-client privilege and work
product protection, analysis of the Court of Federal Claims
disallowance of losses from the DAD transaction, and an update on
Microsoft's request for an evidentiary hearing challenging an
IRS summons.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
