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Tax Refunds Tax Penalties Internal Revenue Service

McDermott Will & Emery

Can the IRS Assert IRC Section 6676’s Erroneous Refund Penalty on Protective Refund Claims?

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We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several times before, but this...more

McDermott Will & Emery

Weekly IRS Roundup June 5 – June 9, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more

Bilzin Sumberg

Emily S. Wilson et al. v. United States: Playing Battleship with the Internal Revenue Service

Bilzin Sumberg on

As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more

McDermott Will & Emery

Weekly IRS Roundup February 25 – March 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

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