September 19, 2016

Focus on Tax Controversy and Litigation



In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s right to raise a partner-level good faith and reasonable cause defense to penalties, the District Court’s decision in Interior Glass, which upheld the constitutionality of section 6707A, the Second Circuit’s decision in United States v. Greenfield, concluding that an IRS summons violated taxpayer’s Fifth Amendment protections against self-incrimination, the Federal Circuit’s decision in Nacchio v. United States which held that a forfeiture payment could not be deducted under section 162, the IRS’ recent announcement to change the CAP Program and Revenue Procedure 2016-45 that announced that the IRS will issue letter rulings on two spinoff-related areas under section 355.

View full memo, Focus on Tax Controversy and Litigation