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Internal Revenue Service Discovery

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.  
EDRM - Electronic Discovery Reference Model

November’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published November 15, 2023 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of...more

Gray Reed

When is an Accountant Forced to Testify Against Their Client?

Gray Reed on

Recently, in a criminal case involving a physician who hired an accountant to prepare and submit certain tax forms to the IRS on her behalf, the court denied attorney-client and work-product privilege claims and ordered the...more

Weber Gallagher Simpson Stapleton Fires &...

What to Know About Reporting Apple Pay, Venmo and Cash App Transactions

Weber Gallagher’s Family Law Group often reviews payments made through popular mobile apps, including Venmo and Apple Pay, in discovery and for support purposes. Clients who utilize one of the many mobile payment platforms...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

Freeman Law

The Tax Court in Brief - February 2021 #3

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of February 15 – February 19, 2021 - Kramer v. Comm’r, T.C....more

Proskauer Rose LLP

ERISA Newsletter - First Quarter 2019

Proskauer Rose LLP on

Editor's Overview - We often talk about the importance of evaluating whether there are any procedural obstacles to plaintiffs pursuing their ERISA claims, particularly in complex, class actions where it may not be...more

Haight Brown & Bonesteel LLP

Discovery Rule Supersedes Tolling of Certain Limitations Periods Due to Fiduciary Relationship Between Client and Professional...

In Choi v. Sagemark Consulting, et al. (No. H041569, filed 11/16/17, certified for publication 12/11/17), the Sixth Appellate District affirmed a trial court’s grant of summary judgment in favor of financial advisor...more

BakerHostetler

U.S. Tax Court Gives Strong Boost to Computer-Assisted Review

BakerHostetler on

On July 13, 2016, in Dynamo Holdings Limited P’ship v. Comm’r, the U.S. Tax Court strongly defended the taxpayer’s use of computer-assisted review in a dispute with the IRS. In a 2014 decision in the same case, the Tax Court...more

McDermott Will & Emery

Tax Court Holds that Inadequate Privilege Log Subjects Putatively Privileged Documents to Disclosure

On May 26, 2015, the Tax Court issued its opinion in Pacific Management Group v. Commissioner, T.C. Memo. 2015-97, holding that a privilege log provided to the Internal Revenue Service (IRS) was inadequate to sustain claims...more

Bracewell LLP

Predictive Coding Sanctioned as an "Expedited and Efficient" Discovery Method by the United States Tax Court

Bracewell LLP on

The volume of electronically stored information (“ESI”) has exploded, often making discovery prohibitively expensive. Supporters of “predictive coding” champion it as a way to reduce significantly the cost of discovery....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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