2011 Decisions Impacting IRS Tax Return Investigations

Decisions in two Courts of Appeals in 2011 bear on defining what constitutes an omission from gross income on a submitted return and what limitations period applies to IRS return investigations. Analyses by the Fourth and Seventh Circuits turned in different ways on principles enunciated in COLONY, INC...

Mayo Intensifies Treasury Reg Authority

The U.S. Supreme Court's recent decision in Mayo Foundation for Medical Education and Research v. United States , 131 S. Ct. 704, 178 L. Ed. 2d 588, 2011 U.S. Lexis 609 (2011), provided guidance, after several decades of litigation, on the degree of deference afforded to agency rules in general and...