On April 3, 2023, the Tax Court ruled in Farhy v. Commissioner1 that the Internal Revenue Service (IRS) lacks the authority to assess penalties under Section 6038(b) of the Internal Revenue Code (the Code) and may not proceed...more
On November 16, 2022, the IRS released a long-awaited update to the procedure for large corporate taxpayers and large partnerships under continuous audit to obtain Qualified Amended Return (QAR) treatment for items disclosed...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more
11/5/2015
/ Administrative Procedure Act ,
Audits ,
Barack Obama ,
Bipartisan Budget ,
Burden of Proof ,
Business Taxes ,
C-Corporation ,
FPAA ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
K-1 ,
New Legislation ,
Partnership Interests ,
Partnerships ,
S-Corporation ,
Statute of Limitations ,
Tax Assessment ,
TEFRA ,
Treasury
Tax controversies often involve voluminous document production and extensive privilege logs from multiple parties. The privilege issues can be complex and involve advice from multiple advisers potentially covering several...more