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June 16, 2015

Focus on Tax Controversy and Litigation

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In addition to a discussion of the Supreme Court’s recent decision in Maryland v. Wynne, this month’s issue features articles about two recent developments on FTC Generator cases, two decisions regarding the attorney-client privilege and the need for a properly detailed privilege log, a recent FSA ruling on the deductibility of an equitable disgorgement payment to the Federal Food and Drug Administration, penalties imposed in Castle Harbour, and a discussion of Notice 2014-58, which provides guidance on codification of the economic substance doctrine under section 7701(o).

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