In this issue:

Taxpayer not liable for accuracy related penalty in Son of BOSS tax shelter case

Overpayment was outside the “look-back” period, and refund claim was thus time barred

Tax Controversy Updates
Overstatement of basis does not trigger six year statute of limitations

Temporary regulations define omission from gross income for purposes of statute of limitations

Recent Guidance
IRS updates appeals mediation procedures

IRS changes procedures for late entity classification elections

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IRS Insights
                                                                                                                                November 2009

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If you have questions or comments about the content of IRS Insights, click on the author's name for contact information or contact:

Julia Lagun
Editor, Deloitte Tax LLP
+1 (202) 879 5364
jlagun@deloitte.com

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