Sep 01, 2015

Focus on Tax Controversy and Litigation



In addition to the discussion of the Tax Court’s decision in Altera, this month’s issue features articles regarding Notice 2015-47 “Basket Options” and Notice 2015-48 “Basket Contracts”, the Federal Circuit Court of Appeals decision is BASR Partnership v. United States that Section 6501(C)(1)’s suspension of the three-year limitation applies only when the taxpayer acts with the requisite intent to evade tax, a recent Circuit Court ruling that upheld the application of the attorney-client privilege and work product protection, analysis of the Court of Federal Claims disallowance of losses from the DAD transaction, and an update on Microsoft’s request for an evidentiary hearing challenging an IRS summons.

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