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IRS Continues to Barrage Taxpayers with New Campaigns

By on Nov 3, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized

On November 3, 2017, the Internal Revenue Service (IRS) Large Business and International (LB&I) division identified 11 new examination compliance “campaigns.” We have extensively discussed LB&I’s “campaign” examination process, including posts on Understanding LB&I “Campaigns” and Run for Cover – IRS Unveils Initial “Campaigns” for LB&I Audits. The IRS identified the 11 new campaigns “through...

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David Kautter Named Acting IRS Commissioner

By on Oct 26, 2017
Posted In Uncategorized

Today, President Trump announced his intention to designate David Kautter to be the Acting Commissioner of Internal Revenue effective November 13, 2017. John Koskinen, the current Commissioner of Internal Revenue, is near the end of his term, which ends on November 12, 2017. The Commissioner’s role is to preside over the nation’s tax system and...

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McDermott’s Tax Controversy Team Garners Tier 1 Ranking in the Legal 500 United States 2017

By on Jun 9, 2017
Posted In Uncategorized

Recently, the Legal 500 US 2017 ranked McDermott’s Tax Controversy practice group as Tier 1. (The Legal 500 category for Tax Controversy is “US Taxes—Contentious.”) Five members of our federal tax controversy team—Todd Welty, Roger Jones, Jean Pawlow, Robin Greenhouse and Andrew Roberson—were specifically mentioned as part of the Firm’s “outstanding” practice. Welty, Jones and...

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McDermott Continues to Receive Top Rankings in Tax in Chambers USA 2017

By on Jun 2, 2017
Posted In Uncategorized

Chambers USA, which releases an annual listing of rankings of law firms and attorneys in various practice areas, has released its 2017 edition. We are honored that Chambers USA has recognized McDermott’s tax practice and several of its attorneys in the latest rankings. A summary of McDermott’s tax rankings is listed below along with a...

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What to Expect During a Change of Administration

By , , and on Jan 25, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Uncategorized

With the inauguration of President Trump, and the accompanying change of administration, the American people have been promised great change in all areas of the federal government. One question we at McDermott have been frequently asked since the election is: what should a taxpayer expect from the Internal Revenue Service (IRS) and the Department of...

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IRS Audits and IRS Appeals — A Year in Review

By on Jan 6, 2017
Posted In Court Procedure Matters, IRS Appeals, IRS Audits, Uncategorized

This year has been marked with substantial changes in the manner in which the Internal Revenue Service (IRS) operates. Shrinking resources and retiring IRS professionals have marred the IRS and its efficiency. The pervasive theme for 2016 was trying to do the job with fewer resources.  For example, IRS audits continue to devolve with standardized...

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Court Opinions – A Year In Review

By on Jan 4, 2017
Posted In Appellate Courts, IRS Guidance, Transfer Pricing Resource, Trial Courts, Uncategorized

Several notable court opinions were issued 2016 dealing with a variety of substantive and procedural matters. In our previous post – Tax Controversy 360 Year in Review: Court Procedure and Privilege – we discussed some of these matters. This post addresses some additional cases decided by the court during the year and highlights some other...

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Court Procedure and Privilege – A Year in Review

By on Jan 3, 2017
Posted In Court Procedure Matters, Uncategorized

This past year has seen a number of important developments in the areas of Tax Court procedure, federal court procedure, and privilege and non-disclosure. As the below cases and posts demonstrate, taxpayers’ reliance on experts, their efforts to protect privileged information, and their efforts to limit sweeping government discovery requests continue to be tested and closely...

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