BNA INSIGHTS: Tax Liens: Treasury’s Uncertain Tax Position?

The Tax Court in a reviewed decision, Intermountain Insurance Service of Vail LLC v. Commissioner, rejected the Internal Revenue Service’s argument that a temporary regulation…

Congress Aware of Issues That Surround Statute of Limitations Provision, Aide Says

Members of Congress are aware of the issues surrounding a controversial provision on the statute of limitations in legislation to require broad new reporting by foreign banks, a lawyer on…

New Law Could Prevent Closing out Reserves for Some Tax Positions, Practitioners Fear

A new tax law seemingly intended to apply only to the statute of limitations for assessments on foreign information filed with the Internal Revenue Service could force financial statement preparers…

Tax Court Says IRS’s Temporary Rules on Partnership Basis Overstatements Invalid

A majority of the U.S. Tax Court May 6 held invalid temporary regulations (T.D. 9466) issued by the Internal Revenue Service defining an overstatement of basis as an…