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Internal Revenue Service Document Productions

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.  
Oberheiden P.C.

IRS/Tax Whistleblower Guide

Oberheiden P.C. on

Anyone who has obtained evidence that a person or company is committing tax fraud or evasion can become a whistleblower by reporting it to the Internal Revenue Service (IRS). Due to the volume of reports that the agency...more

Association of Certified E-Discovery...

Does FRE 502(d) Allow a Party to Shift the Privilege Burden?

[Editor’s Note: This article has been republished with permission. It was originally published December 20, 2023 on the eDiscovery Assistant Blog] In Episode 127, on the ACEDS and eDiscovery Assistant #CaseoftheWeek, Kelly...more

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

A Guide to Office Audits with the IRS

Gray Reed on

When a tax return has been selected for office examination, generally the examination of the return will be conducted at the office of the IRS.  Normally a taxpayer will find an office examination has begun when he or she has...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

Skadden, Arps, Slate, Meagher & Flom LLP

"Cost-Efficient Alternatives for Document Production Gaining Traction"

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

BakerHostetler

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

BakerHostetler on

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

BakerHostetler

Ninth Circuit Holds that Fifth Amendment Does Not Shield Taxpayer's Attorney from Forced Production of Client-Taxpayer's Records

BakerHostetler on

Applying the “foregone conclusion” exception to the Fifth Amendment privilege against self-incrimination, the Ninth Circuit held on January 8, 2013, that the IRS could force a taxpayer’s criminal defense attorney to turn over...more

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