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Showing posts with label IRS Summons - Powell Standard. Show all posts
Showing posts with label IRS Summons - Powell Standard. Show all posts
Saturday, July 9, 2022

4th Circuit Holds the Tax Partnership Receiving an Administrative Summons is Different Than its Representative for Purposes of § 7602(d) (7/9/22; 7/12/22)

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In Equity Inv. Assocs., LLC v. United States , 40 F.4th 156 (4th Cir. July 8, 2022), CA 4 here  and GS here , the Court held that, for purpo...
Monday, October 4, 2021

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

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The district court has enforced the IRS summons issued to the Delaware Department of Insurance (“DDOI”) for information and documents on abo...
Monday, July 19, 2021

Magistrate Judge Recommends Enforcement of IRS Summons to Delaware Dept of Insurance for Information Filed by Micro-Captives (7/19/21)

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In  United States v. Del. Dep't of Ins. , Civil Action No. 20-829-MN-CJB, 2021 U.S. Dist. LEXIS 132716 (D. Del. July 16, 2021),  here , ...
Wednesday, January 22, 2020

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

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After publishing this blog entry, a new article was published about Microsoft's transfer pricing planning and the audit.  I discuss tha...
Thursday, October 1, 2015

Second Circuit Opinion Affirming Denial of Motion to Quash Summons (10/1/15)

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We have studied IRS summonses and summons enforcement in the class.  See Student edition pp. 271 - 282.  A recent nonprecedential opinion fr...