Tax Law Center News Items

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Tax Law Center News Items

Eighth circuit upholds IRS substantial portion test for deferral of crop insurance proceeds.

SUMMARY: Eighth circuit upholds IRS substantial portion test for deferral of crop insurance proceeds.

TOPIC: Gross Income

SECTION: 451. General rule for taxable year of inclusion

CITATION: Nelson v. CIR, 568 F3d 662 (8th Cir. 2009)

DATE: 2009-06-09

DOC TYPE: Cases

EXPLANATION:

Attorney work product privilege protects workpapers from disclosure.

SUMMARY: Attorney work product privilege protects workpapers from disclosure.

TOPIC: Privileges and workpapers

SECTION: 7602. Examination of books and witnesses

CITATION: U.S. v. Deloitte & Touche USA LLP, 2009-1 U.S.T.C. 50,450, (DC D.C. 2009)

DATE: 2009-06-07

DOC TYPE: Cases

EXPLANATION:

IRS fails to prove tax shelter exception to tax practitioner privilege.

SUMMARY: IRS fails to prove tax shelter exception to tax practitioner privilege.

TOPIC: Privileges and workpapers

SECTION: 7525. Confidentiality privileges relating to taxpayer communications

CITATION: Countryside Limited Partnership, v. Commissioner., 132 T.C. No. 17, (Jun. 8, 2009)

DATE: 2009-06-07

DOC TYPE: Cases

EXPLANATION:

IRS suspends 2009 reporting of foreign bank accounts by persons doing business in the united states.

SUMMARY: IRS suspends 2009 reporting of foreign bank accounts by persons doing business in the united states.

TOPIC: Tax Return Preparation

SECTION: 6011. General requirement of return, statement, or list

CITATION: IR-2009-58, June 5, 2009

DATE: 2009-06-04

DOC TYPE: IRS News Item

EXPLANATION:

IRS identifies U.S.-source FDAP withholding as tier 1 compliance issue.

SUMMARY: IRS identifies U.S.-source FDAP withholding as tier 1 compliance issue.

TOPIC: Foreign Tax Issues

SECTION: 1441. Withholding of tax on nonresident aliens

CITATION: 2009ARD 106-6 (Jun. 3, 2009)

DATE: 2009-06-02

DOC TYPE: IRS News Item

EXPLANATION:

IRS associate area counsel states that right to renew season tickets not property IRS can levy on but personal seat licenses may be subject to levy.

SUMMARY: IRS associate area counsel states that right to renew season tickets not property IRS can levy on but personal seat licenses may be subject to levy.

TOPIC: Collection

SECTION: 6321. Lien for taxes

CITATION: Field Attorney Advice 20092102F, 2009ARD 105-3 (Jun. 2, 2009)

DATE: 2009-06-01

DOC TYPE: Chief Counsel Advice (CCA)

EXPLANATION:

Estate wins partial exclusion of assets transferred to family limited partnership.

SUMMARY: Estate wins partial exclusion of assets transferred to family limited partnership.

TOPIC: Estate and Gift Tax

SECTION: 2036. Transfers with retained life estate

CITATION: Estate of Miller v. Commissioner, T.C. Memo. 2009-119, 97 T.C.M. 1602, (May 27, 2009)

DATE: 2009-05-26