Daniel Schlueter

Daniel Schlueter

Sutherland Asbill & Brennan LLP

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Legal Alert: The Tax Court Approves the Use of Predictive Coding

On September 17, the U.S. Tax Court, in Dynamo Holdings LP v. Commissioner, 143 T.C. No. 9 (Sept. 17, 2014), held that a taxpayer could use predictive coding, over the objection of the Internal Revenue Service (IRS), to...more

9/30/2014 - Attorney-Client Privilege Discovery Electronically Stored Information Federal Rules of Civil Procedure IRS Predictive Coding Tax Court Work Product Privilege

Legal Alert: The 2013 Tax Litigation Year in Review: Important Events

As we look forward to 2014, we take a look back at the top 10 important tax controversy issues making the news in 2013 that may have continuing importance in the future....more

1/31/2014 - Banks IRS SCOTUS United States v Woods UTPs Valuation Wells Fargo

Legal Alert: U.S. Supreme Court Resolves Circuit Split: Holds Valuation Misstatement Penalty Applies in Partnership Tax Shelter...

On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more

12/20/2013 - Asset Valuations Income Taxes IRS Jurisdiction Material Misstatements Partnerships Penalties SCOTUS Tax Shelters TEFRA Underpayment

U.S. District Court Orders Disclosure of Tax Accrual Workpapers, but Protects Opinion Work Product Information

On June 4, 2013, the U.S. District Court for the District of Minnesota held that certain information contained in tax accrual workpapers must be disclosed by the taxpayer pursuant to an Internal Revenue Service (IRS) summons,...more

6/19/2013 - Attorney-Client Privilege Disclosure Requirements IRS Summons Tax Accrual Workpapers UTPs Work Product Privilege

IRS Pressures Build: Budgetary Constraints, the Aging IRS Workforce and Changes in IRS Focus

On April 10, 2013, President Obama released his proposed Fiscal Year 2014 Budget of the U.S. Government. The budget calls for an increase in funding for the Internal Revenue Service (“IRS”), which has faced budget cuts in...more

4/25/2013 - Audits Federal Budget IRS Layoffs OVDP Recruitment Policies Retirement Plan Spending Cuts

Legal Alert: A Trend Emerging? District Court Disallows $1 Billion of Deductions

Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more

4/4/2013 - Dow Chemical IRS Partnerships Tax Deductions Tax Fraud TEFRA

Legal Alert: The 2012 Tax Litigation Year in Review: Important Events

The year 2012 was quite an interesting one for tax controversy. Whereas 2011 brought a win for the Treasury on deference issues in Mayo Foundation for Medical Ed. v. United States, 131 S. Ct. 704 (2011), 2012 was the year...more

1/16/2013 - Administrative Procedure Act Dominion Resources FICA Taxes H&M Hewlett-Packard IRS Mayo Foundation for Medical Ed Net Investment Income PepsiCo Quality Stores SCOTUS Severance Pay

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