On November 2, 2015, President Obama signed the Budget Act of 2015 (the “2015 Budget Act”), which makes significant amendments to the procedural rules governing federal income tax audits and judicial proceedings that apply to...more
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
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