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Internal Revenue Service Tax Litigation

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.  
Foodman CPAs & Advisors

Mediación con el IRS

El 6/20/24, el IRS emitió el Consejo Fiscal 2024-59 para alertar a los contribuyentes que la mediación con el IRS puede ayudarlos a resolver sus problemas tributarios de manera temprana y efectiva. El IRS afirma que la...more

Foodman CPAs & Advisors

Mediation with the IRS

On 6/20/24, the IRS issued Tax Tip 2024-59 to alert taxpayers that mediation with the IRS can assist taxpayers to solve their tax issues early and effectively. IRS states that mediation with the IRS can be a more...more

Morris, Manning & Martin, LLP

Beware: More ERC Denial Letters in the Pipeline

Employee Retention Credits (ERCs) are critical for many ongoing businesses. Many businesses are still waiting on the IRS to pay out the ERC claims; others anticipate the IRS will attempt to deny or claw back the claims,...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

McDermott Will & Emery

Tax Court Rules Limited Partners May Be Subject to Self-Employment Tax

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On November 28, 2023, the US Tax Court granted partial summary judgment in favor of the Internal Revenue Service (IRS) in Soroban Capital Partners LP v. Commissioner and held that “limited partners” are defined...more

Vinson & Elkins LLP

The Heat Is on for Large Partnership Audits

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Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more

Gray Reed

Tax Court Confirms Taxpayer’s Right to Dismiss Their Own Lawsuit

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An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.” ...more

Woods Rogers

A Win for Taxpayers: Federal Circuit Court of Appeals Loosens Tax Court Jurisdictional Limitations

Woods Rogers on

On July 19, 2023, the United States Court of Appeals for the Third Circuit released an opinion in the matter of Culp v. Commissioner of Internal Revenue (PDF). The ruling stated the 90-day filing period for Tax Court...more

McDermott Will & Emery

IRS Proposes New Regulations to Settle Supervisory Approval of Penalties Requirements

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The Internal Revenue Service (IRS) has proposed regulations to clarify the rules regarding supervisory approval of federal civil tax penalties under IRC Section 6751(b). Since Chai v. Commissioner, there has been a...more

McDermott Will & Emery

Weekly IRS Roundup March 13 – March 17, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more

Lewis Roca

Review of 2022 Arizona Tax Highlights

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ARIZONA TO IMPLEMENT 2.5% FLAT TAX AHEAD OF SCHEDULE - Governor Doug Ducey announced that Arizona will implement its new 2.5% flat income tax rate on January 1, 2023, a full year ahead of schedule. According to Gov. Ducey,...more

Buckingham, Doolittle & Burroughs, LLC

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

Freeman Law

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

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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....more

Freeman Law

Tax Court in Brief | Scheider v. Comm’r | Deficiency for Unreported Income; Burdens of Proof

Freeman Law on

Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 | Greaves, J. | Dkt. No. 21002-16 Clark Raymond & Company, PLLC v. Comm’r, T.C. Memo. 2022-105 |...more

McDermott Will & Emery

IRS Appeals Revises Initial Contact Letter

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The Internal Revenue Service Independent Office of Appeals (IRS Appeals) is the administrative forum for taxpayers to attempt to resolve tax disputes prior to litigation. Subject to certain exceptions, taxpayers can file a...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - September 2022

The September Monthly Minute reports on the IRS’ new amendment extension deadline with respect to coronavirus-related distributions and qualified disaster distributions, a recent $131.8 million settlement stemming from...more

Freeman Law

The Taxpayer Bill of Rights

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The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more

McDermott Will & Emery

Sixth Circuit Denies Proceeds Regulation Rehearing Request, Sets Up a Circuit Split

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The US Court of Appeals for the Sixth Circuit recently denied a taxpayer’s request for a rehearing en banc in Oakbrook Land Holdings, LLC v. Commissioner, No. 20-2117, leaving a highly contested conservation easement...more

McDermott Will & Emery

Will the Supreme Court Rule on Whirlpool’s Subpart F Income Case?

A war is currently waging in the tax world over when courts should give deference to the US Department of the Treasury’s regulations. (We have written extensively on this subject...) However, another potential war looms: Can...more

McDermott Will & Emery

IRS Appeals Acknowledges Massive Backlog of Cases, Plans to Catch Up

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In a memorandum dated April 19, 2022, the Internal Revenue Service’s (IRS) Independent Office of Appeals (IRS Appeals) acknowledged that it has a large backlog of cases that is slowing down the process of resolving cases with...more

McDermott Will & Emery

Late CDP Petitions May Still Be Entitled to Tax Court Review

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In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and...more

McDermott Will & Emery

Sixth Circuit Sides with Taxpayer in APA Challenge to Reportable Transaction Regime

We previously posted about the US Supreme Court’s opinion in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. In that post, we noted...more

McDermott Will & Emery

IRS Chief Counsel Signals Increased Tax Enforcement

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The Internal Revenue Service (IRS) Chief Counsel is the chief legal advisor to the Commissioner of Internal Revenue on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Laws....more

McDermott Will & Emery

Implications of the Sixth Circuit's Whirlpool Opinion

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The US Court of Appeals for the Sixth Circuit recently issued its opinion in Whirlpool Financial Corporation & Consolidated Subsidiaries v. Commissioner, affirming the decision made by the US Tax Court. The Tax Court held...more

Holland & Hart LLP

Tax Court Denies Coca-Cola's Request for Reconsideration in Pivotal Transfer Pricing Case

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The Tax Court has denied Coca-Cola’s request to file an out of time motion for reconsideration of the Court’s November 2020 adverse transfer pricing decision. Coca-Cola filed its motion 196 days after the Tax Court served its...more

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