Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 20 – May 24, 2019.
May 20, 2019: The IRS issued a news release announcing the release of its
Tax Controversy 360
McDermott’s Real-Time Tax Disputes Insights
Tax Controversy 360, published by McDermott Will & Emery, focuses on issues related to tax disputes and controversies involving the Internal Revenue Service and other tax authorities. The blog covers topics such as IRS enforcement actions, audit strategies, tax planning risks for high-net-worth individuals, regulatory updates, and procedural developments in tax litigation. It also addresses the impact of legislative changes and administrative guidance on tax controversy practice, including insights on private foundations, tax court procedures, and tax implications of current events like the COVID-19 pandemic. The content is aimed at tax professionals, advisors, and taxpayers navigating complex tax dispute environments.
Latest from Tax Controversy 360 - Page 12
Tax Court Announces Limited Entries of Appearance
The concept of limited scope representation is not a new one in the legal arena. Rule 1.2(c) of the ABA Model Rules of Professional Conduct provides that “A lawyer may limit the scope of the representation if the limitation is…
A Notice of Deficiency Is Not Set in Stone
By Le Chen & Kevin Spencer
A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the Notice…
IRS LB&I Sharpens Its Risk Analysis, Announces Large Corporate Compliance (LCC) Program
Last week, the IRS unveiled a major change in how it identifies its biggest and most complex large corporations for examination. The move is part of the IRS’s broader efforts toward “portfolio management”—maximizing and modernizing its resources to focus upon…
Sacked in Tax Court! Procedural Missteps by the IRS Leave the Government’s Blindside Exposed
In Kearse v. Commissioner, T.C. Memo 2019-53, the Tax Court held the Internal Revenue Service (IRS) abused its discretion as part of the taxpayer’s Collection Due Process hearing (CDP hearing) because the Appeals officer failed to properly verify that…
Weekly IRS Roundup May 13 – May 17, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13 – May 17, 2019.
May 13, 2019: The IRS released a statement regarding the National Taxpayer Advocate position…
Weekly IRS Roundup May 6 – 10, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019.
May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue Procedure 75-50 in order…
Weekly IRS Roundup April 29 – May 3, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29 – May 3, 2019.
April 29, 2019: The IRS issued a news release urging taxpayers who had not…
Weekly IRS Roundup April 22 – 26, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 22–26, 2019.
April 22, 2019: In an effort to reduce paperwork and respondent burden the IRS requested public comments…
What Happens At Exam, Stays At Exam!
A recent case decided by the US Tax Court reminds us that when you litigate a case in Tax Court, what happened during the Internal Revenue Service (IRS) examination and Appeals bears very little relevance (if any) once you get…