In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1,
Tax Controversy 360
McDermott’s Real-Time Tax Disputes Insights
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CARES Act Refund Claim Guidance
The Coronavirus Aid, Relief and Economic Security Act, or CARES Act, provides tax relief to taxpayers in certain situations. Some of these provisions may generate refunds for prior years, such as the relaxation of restrictions on the use of…
IRS Failed to Prove Supervisory Approval For Penalty Based Upon Redacted Document
In a recent order in the The Cannon Corp. v. Commissioner, No. 12466-16, the US Tax Court (Tax Court) held that a redacted email from a revenue agent’s supervisor to the agent regarding a notice of deficiency was not…
Weekly IRS Roundup March 30 – April 3, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 30 – April 3, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…
Weekly IRS Roundup March 23 – 27, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 23 – 27, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page…
No IDR Enforcement During COVID-19
Yesterday, the Internal Revenue Service (IRS) announced in a memorandum to all Large Business & International (LB&I) division employees that it was suspending the normal Information Document Request (IDR) procedures. The letter suspends enforcement until July 15, 2020; however, LB&I…
IRS to Temporarily Adjust Operations and Key Compliance Functions
On March 25, 2020, the Internal Revenue Service (IRS) announced a new People First Initiative designed to provide relief to taxpayers on a variety of issues ranging from easing payment guidelines to postponing compliance actions in light of the challenges…
Taxpayer Victory in an IRC Section 199 Contract Manufacturing Case
Recently, the US Federal District Court for the Southern District of Iowa in Meredith Corp. v. United States, No. 4:17-cv-00385 (S.D. Iowa Mar. 20, 2020), held that a magazine publisher was entitled to refund of federal income tax based for…
US Tax Court Cancels Remainder of Spring Trial Sessions
After cancelling several trial sessions for March 2020 and April 2020, and closing its building until further notice, the US Tax Court (Tax Court) has announced that the remainder of its trial sessions through the end of June 2020…
Weekly IRS Roundup March 16 – 20, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 16 – 20, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page…