News & Analysis as of

Internal Revenue Service Federal Rules of Civil Procedure

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Cozen O'Connor

Notice of Appeal - A quarterly newsletter reviewing Third Circuit opinions impacting white collar defense lawyers - March 2024

Cozen O'Connor on

Defendant and his co-conspirators firebombed an informant’s house and killed several individuals. Six weeks into their trial on related charges, the Government disclosed that one of the defense attorneys previously worked as...more

Freeman Law

Executor Seeks Refund of Fiduciary Income Taxes, and The Application of Iqbal/Twombly to Defensive Pleadings in Tax Cases

Freeman Law on

The executor of the Estate of Tamir Sapir is seeking a refund of more than $25 million of fiduciary income tax alleged to have been overpaid to the Internal Revenue Service (“IRS”). While the refund suit is currently teed up...more

Proskauer Rose LLP

ERISA Newsletter - Third Quarter 2017

Proskauer Rose LLP on

Editor's Overview - As we have observed on other occasions, the ERISA class action plaintiffs' bar has, for several years now, honed in on 401(k) plan fiduciaries and their decisions to select and retain investment options...more

WilmerHale

Second Circuit Clarifies Common Legal Interest and Work Product Doctrines for Material Shared Among Transacting Parties

WilmerHale on

The U.S. Court of Appeals for the Second Circuit recently ruled that the “common interest” doctrine protects legal and tax liability analysis prepared for a client and subsequently shared with a consortium of banks providing...more

Manatt, Phelps & Phillips, LLP

Employment Law - July 2015

The Impact of National Same-Sex Marriage for Employers - Why it matters: How will employers feel the impact of the U.S. Supreme Court’s decision in Obergefell v. Hodges? The landmark ruling that the Fourteenth...more

Eversheds Sutherland (US) LLP

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

McDermott Will & Emery

District Court Accords Work Product Protection to Taxpayer Documents Prepared during a Transaction’s Planning Stages

McDermott Will & Emery on

The U.S. District Court for the District of Delaware recently interpreted the work product privilege in a manner favorable to taxpayers, ruling that documents can be prepared “in anticipation of litigation” even if created...more

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