Newsletter
| August 17, 2009
Focus on Tax Controversy and Litigation (Volume II, Issue 6)
In This Issue:
-
United States v. Textron: First Circuit, Sitting En Banc, Denies Work Product Protection to Tax Accrual Workpapers
- IRS Updates Guidance Regarding FBAR Filingsand Voluntary Disclosures
- UBS and US Settle, But Disclosureof Settlement Details Delayed
- Treasury Issues Final Regulations Suspending Running of Period of Limitations During a Proceeding to Enforce or Quash a Designated or Related Summons
- D.C. Circuit Court of Appeals Revives Lawsuit Challenging IRS Notice 2006-50
- Abbott Laboratories: Refund and Assessment Limitations Periods with Respect to FSCs
- Court of Federal Claims Again Finds Section 1.752-6 of the Treasury Regulations Invalid
- Extended Limitations Period Held Inapplicable Where Taxpayer Overstates Basis
- Court Rejects Passive Loss Limits Applicable to LLC Interests
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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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