This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
Recently announced changes to the Internal Revenue Service (IRS) Large Business and International (LB&I) Division’s examination process include a requirement that the audit team issue an Information Document Request (IDR)...more
On September 17, the U.S. Tax Court, in Dynamo Holdings LP v. Commissioner, 143 T.C. No. 9 (Sept. 17, 2014), held that a taxpayer could use predictive coding, over the objection of the Internal Revenue Service (IRS), to...more
As we look forward to 2014, we take a look back at the top 10 important tax controversy issues making the news in 2013 that may have continuing importance in the future....more
On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more
12/20/2013
/ Asset Valuations ,
Income Taxes ,
IRS ,
Jurisdiction ,
Material Misstatements ,
Partnerships ,
Penalties ,
SCOTUS ,
Tax Shelters ,
TEFRA ,
Underpayment
On June 4, 2013, the U.S. District Court for the District of Minnesota held that certain information contained in tax accrual workpapers must be disclosed by the taxpayer pursuant to an Internal Revenue Service (IRS) summons,...more
On April 10, 2013, President Obama released his proposed Fiscal Year 2014 Budget of the U.S. Government. The budget calls for an increase in funding for the Internal Revenue Service (“IRS”), which has faced budget cuts in...more
Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more
The year 2012 was quite an interesting one for tax controversy. Whereas 2011 brought a win for the Treasury on deference issues in Mayo Foundation for Medical Ed. v. United States, 131 S. Ct. 704 (2011), 2012 was the year...more
1/16/2013
/ Administrative Procedure Act ,
Dominion Resources ,
FICA Taxes ,
H&M ,
Hewlett-Packard ,
IRS ,
Mayo Foundation for Medical Ed ,
Net Investment Income ,
PepsiCo ,
Quality Stores ,
SCOTUS ,
Severance Pay