This month’s newsletter also features articles discussing Revenue Procedure 2013 32, which restricts PLRs for spin-offs and other corporate nonrecognition transactions, a Florida district court’s holding that the Administrative Procedure Act did not bar its review of IRS adjustments made to partnership returns that included penalties despite an IRS Announcement providing waiver of penalties, and the SEC’s novel, but successful effort to seek disgorgement in the form of unpaid federal income taxes in SEC v. Wyly.
