Newsletter
| July 29, 2010
Focus on Tax Controversy and Litigation (Volume III, Issue 5)
In This Issue:
- D.C. Circuit Rejects Categorical Exceptions to Work Product Protection, Finds Protection Not Waived by Disclosure to Independent Auditors
-
Anschutz Co. v. Commissioner: Tax Court Holds Taxpayer Must Recognize Some Gain from Integrated Derivatives Transaction, but Finds No Constructive Sale of Stock
- Tenth Circuit Overturns District Court in Sala Son of BOSS Case, Finds Transaction Lacked Economic Substance
- Federal Rules of Civil Procedure Amended to Protect Drafts of Expert Reports from Discovery
- IRS Issues New Regulations for Tax-Exempt Parties Involved in Prohibited Tax Shelters
- Tax Court Holds that Transfer of Stock Is a Sale, Not a Loan
- Tax Court Holds that It Has Jurisdiction to Review IRS Denial of Whistleblower Awards
- Dodd-Frank Act Exempts Swaps from Mark-to-Market Regime
For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:
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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