In ILM 201146017 (10/14/11), here , the IRS concludes that it may summons a taxpayer's electronic data files (or backup files) in order to obtain associated metadata. That is the bottom-line conclusion, but the ILM applies the rule in several ... Read More

In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large... Read More

In a recent speech at the mid-year conference of the Tax Executives Institute, IRS Deputy Commissioner Steven T. Miller laid out the framework for the future of IRS corporate audits. To borrow Mr. Miller's own assessment, this is bad news for large... Read More

In ILM 201146017 (10/14/11), here , the IRS concludes that it may summons a taxpayer's electronic data files (or backup files) in order to obtain associated metadata. That is the bottom-line conclusion, but the ILM applies the rule in several... Read More