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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 H&M Hewlett-Packard IRS Mayo Foundation for Medical Ed Net Investment Income PepsiCo Quality Stores SCOTUS Severance Pay

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