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US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

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US Tax Disputes

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Partnerships/TEFRA

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IRS Issue BBA Guidance to Office of Appeals

By Jeff Erney
  • IRS
  • IRS Administration
  • Partnerships/TEFRA

Who Qualifies as a Partner under the New BBA Regulations

By Jeff Erney
  • General
  • IRS
  • IRS Administration
  • Partnerships/TEFRA

IRS Issues Final Regulations on BBA Partnership Audit Regime

By Jeff Erney
  • IRS
  • IRS Administration
  • Partnerships/TEFRA

Substantial Changes to Partnership Tax Audit Procedures will Severely Impact Partner Liability and Rights Before the IRS

By Jeff Erney
  • Partnerships/TEFRA

IRS Urges Partnerships to Amend Partnership Agreements To Address Expanded Role of Partnership Representatives

By Jeff Erney
  • Partnerships/TEFRA
  • Penalties and Reasonable Cause

SCOTUS Struggles with TEFRA Jurisdiction: Oral Arguments in United States v. Woods

By John Harrington and Marc Teitelbaum
  • Partnerships/TEFRA
  • Penalties and Reasonable Cause

Jurisdiction to Dispute Penalties: Partner v. Partnership-Level Proceedings

By John Harrington and Marc Teitelbaum
  • Partnerships/TEFRA
  • Penalties and Reasonable Cause

The Eighth Circuit Weighs in on Whether Outside Basis is an Affected Item at the Partner Level

By Marc Teitelbaum and John Harrington

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