This doctrine allows taxpayers to “unwind” a tax transaction.
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TOPICS / TAX
IRS practice & procedure
“Be on the lookout” lists gone from IRS reviews of Sec. 501(c)(4) applications
Two years after finding the IRS used inappropriate criteria when reviewing applications for tax-exempt status under Sec. 501(c)(4) and delayed the processing of some applications, the TIGTA issued a follow-up report to check on the IRS’s progress in eliminating the controversial practices.
Final regs. provide rules for assessment limitation period for undisclosed listed transactions
Generally, the IRS has three years from the later of the date the return was filed or the original due date of the return to assess tax.
Gross income omissions and the 6-year tax assessment period
How taxpayers can guard against doubling the statute-of-limitation period for the IRS to assess tax.
What to do when your client receives a summons
This column addresses summonses when issued in taxpayer examinations and is not designed or intended to be a full articulation of the significant legal implications of a summons or its enforcement.
IRS realigns compliance operations
The IRS in November completed reorganization of its compliance operations serving individual and small business taxpayers.
IRS updates accounting method change procedures
The new rules apply to automatic and nonautomatic accounting method changes and include a list of automatic changes that do not require IRS consent.
Budget cuts may force IRS furlough days again
The IRS warned its employees that budget cuts may require it to furlough employees for two days sometime during this fiscal year.
AICPA provides feedback on tax reform proposals
The AICPA urged Rep. Paul Ryan, the new chair of the House Ways and Means Committee, to follow the AICPA’s principles of good tax policy to guide tax reform.
TIGTA: Process for complaints against preparers is too slow
The Treasury Inspector General for Tax Administration said in Rep’t No. 2014-40-056 that its audit indicated the IRS does not timely process complaints it receives against tax return preparers.
IRS proposes scrapping COD nonpayment testing period
The Service says the 36-month period for reporting cancellation-of-debt income is ineffective and prone to confusion.
Congress passes tax extender legislation
Included in the extended provisions are the research and development credit, bonus depreciation and higher limits under Sec. 179. The bill now goes to the president for his signature.
CPA practitioners sue to stop PTIN fees
Plaintiffs say the $64.25 first-time fee and $63 annual renewal provide no special benefit under federal law.
AICPA identifies problems with IRS’s electronic signature rules
Verification through records checks and authentication questions may risk clients’ data security and be impractical for some.
Can practitioners give up their email disclaimers?
In June, the IRS finalized changes to Circular 230, Regulations Governing Practice Before the Internal Revenue Service, affecting the provision of written tax advice and certain other related provisions.
G-20 leaders commit to automatic exchange of tax information
“Profits should be taxed where economic activities deriving the profits are performed and where value is created”—so said the leaders of the G-20 major economies as they endorsed the Organisation for Economic Co-operation and Development’s (OECD’s) global standard for automatic exchange of tax information at the G-20 summit in Brisbane,
Whistleblower awards widened
Final rules expand the definitions of collected proceeds and eligible individuals, and specify the criteria for award amounts. Comprehensive final regulations issued in August provide rules for whistleblower awards under Secs. 7623(a) and (b), as well as rules governing the disclosure of return information under Sec. 6103(h) to pursue these
New IRS appeals process launched
Cases lacking documentation or adherence to procedural requirements or that have new taxpayer information will be returned to Examination. In September, the IRS Office of Appeals began a policy of hearing only cases that are fully developed; hearing officers will not do their own investigations and will send any new
Jeopardy and termination assessment cases
In some circumstances, the IRS may resort to a series of procedures known as jeopardy or termination assessment and collection. If the IRS believes that the collection of an unassessed liability is in jeopardy, it may take steps to begin collection proceedings without following the normal assessment and collection procedures
Changes made to IRS streamlined offshore compliance procedures
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed
Features
FROM THIS MONTH'S ISSUE
4 ways solo practitioners can stand out
Five years ago, a grieving Angel Zhen started his own CPA firm with no clients and no revenue. Today, he has 300 clients, $600,000 in revenue and 12 weeks of annual vacation. In this JofA article, he shares how he set up his firm and how you could do the same.
From The Tax Adviser
April 30, 2026
Current developments in taxation of individuals: Part 2
April 30, 2026
