Newsletter
| July 21, 2009
Focus on Tax Controversy and Litigation (Volume II, Issue 5)
In This Issue:
- Despite Wrapping Up Negotiations, the US-Switzerland Information Exchange Agreement Remains Elusive
- Current Developments in UBS Litigation
- IRS Disallows Section 29 Credits Derived from Fictitious Methane Gas Sales
- Hawaii Tightens Tax Enforcement Laws
- Valero: The Other Side of Countryside
- U.S. District Court for the District of Columbia Follows Trend to Regard Tax Accrual Workpapers as Protected Under Work Product Doctrine
- Eleventh Circuit Reaffirms Taxpayer’s Right to Question IRS Summonses
- Clearmeadow: Court of Federal Claims Upholds Overvaluation Penalty Against Taxpayer Using Son of BOSS Strategy
- Federal Jury Rejects Altria Group’s $24 Million Refund Claim
- Sovereign Bancorp v. United States: Bank Seeks Refund Following IRS Denial of Foreign Tax Credits
- Second Circuit Rules Tax Court Erred in Interest Abatement, Refund Ruling
- Supreme Court Considers Constitution’s Tonnage Clause
- United States v. McFerrin: Fifth Circuit Rules for Taxpayer in a Research Credit Substantiation Case
This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
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