Tag Archives: IRS audits

IRS Rules (Again) That Taxpayers Are Not Entitled to Claimed Refined Coal Credits

In a highly-anticipated Technical Advice Memorandum (TAM) dated March 23, 2017 and released on July 21, 2017, the Internal Revenue Service (IRS) ruled that two taxpayers who had invested in a Limited Liability Company that owned and operated a refined coal facility (the LLC) were not entitled to refined coal production credits they had claimed … Continue Reading

Are You Required to Disclose Supporting Legal Authorities During Discovery?

Discovery in tax litigation can take many different forms, including informal discovery requests (in the US Tax Court), request for admissions, interrogatories and depositions. In addition to obtaining facts, litigants frequently want to know the legal authorities on which the other side intends to rely. Over the years, we have seen numerous requests, both during … Continue Reading

Formal Document Requests – The IRS’s Tool for Collecting “Foreign-Based Documentation”

One important feature of every audit is the request and collection of relevant taxpayer materials by the Internal Revenue Service (IRS). Such materials are typically collected through the rules and procedures associated with an Information Document Request (IDR).  However, for audits that involve the collection of foreign-based documentation, the Internal Revenue Code (Code) provides a … Continue Reading
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