Pages

▼
Showing posts with label IRS Summons - Enforcement. Show all posts
Showing posts with label IRS Summons - Enforcement. Show all posts
Thursday, May 23, 2024

Eaton Corp. Loses Summons Enforcement Summons Skirmish with IRS over Foreign Employee Valuations (5/23/24)

›
In United States v. Eaton Corp. (N.D. Oh Case No. 1:23-MC-00037 Doc 22 Opinion & Order dated 5/16/24), CL here , the Court rejected Eat...
Monday, October 4, 2021

District Court Enforces Summons to Delaware Dept of Insurance for Micro-Captive Information (10/4/21)

›
The district court has enforced the IRS summons issued to the Delaware Department of Insurance (“DDOI”) for information and documents on abo...
Wednesday, January 22, 2020

Microsoft Summons Enforcement on Transfer Pricing "Planning" - Mixed on Privilege Claims (1/22/20)

›
After publishing this blog entry, a new article was published about Microsoft's transfer pricing planning and the audit.  I discuss tha...
Saturday, January 18, 2014

Supreme Court Grants Cert to Consider Summons Opponent's Right to Question IRS Personnel re Reason for Summons (1/18/14)

›
The Supreme Court granted certiorari in United States v. Clarke , 517 Fed. Appx. 689, 2013 U.S. App. LEXIS 7773 (11th Cir. 2013), here .  Se...
Friday, December 13, 2013

Is a Party Entitled to a Hearing in a Summons Enforcement Case Based Solely on Allegations of Improper Purpose? (12/13/13)

›
The United States has petitioned the Supreme Court in United States v. Clarke , 517 Fed. Appx. 689, 2013 U.S. App. LEXIS 7773 (11th Cir. 20...
Tuesday, August 21, 2012

IRS Won Some / Lost Some on Privilege Assertions in Summons Enforcement (8/20/12)

›
In United States v. Eaton , 2012 U.S. Dist. LEXIS 115003 (ND OH 2012), here , the IRS was not pleased with the taxpayer's assertion of p...