Newsletter
| August 27, 2010
Focus on Tax Controversy and Litigation (Volume III, Issue 6)
In this issue:
- Tax Court Finds Leveraged Partnership Transaction Is a Disguised Sale, Imposes Accuracy-Related Penalty
- IRS to Reorganize the Large and Mid-Size Business Division to Bring Greater Focus on International Issues
- “FTC Generator” Case Update
- Bankruptcy Petition No Bar to Tax Court Jurisdiction
- Internal Documents Reveal IRS Views on Erroneous Refund Claim Penalty
- IRS Appeals Seeks Quicker Resolution of Research Credit Cases
- OECD Approves Updates to the Model Tax Convention and 1995 TransferPricing Guidelines
- Treasury Proposes Extension of Circular 230 to Return Preparers
- Upcoming Events
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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