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TOPICS / PROCEDURE

Economic Substance Doctrine Clarified

The IRS provided guidance defining "transaction" for purposes of applying the Sec. 7701(o) economic substance doctrine and "similar rule of law" for purposes of the Sec. 6662(b)(6) accuracy-related penalty.

President Signs Tax Extenders Into Law

President Barack Obama on Friday signed into law the Tax Increase Prevention Act of 2014, which retroactively extends more than 50 expired tax provisions through 2014.

Congress Passes Tax Extender Legislation

The Senate passed a bill to retroactively extend more than 50 expired tax provisions through 2014, by a vote of 76–16 on Tuesday evening. The extender bill passed the House of Representatives on Dec. 3, and it now goes to President Barack Obama for his signature.

Six-Year Statute of Limitation Applies to Assessment

The Tax Court held that the six-year statute of limitation of Sec. 6501(e)(1)(A) applied to an assessment of tax based on a distribution from an ESOP because the taxpayer had not adequately disclosed the distribution on his tax return.

Tax Simplification: Key to Fighting Tax Return Identity Theft

Identity theft and tax simplification are high priorities for members of Congress, the IRS, and all taxpayers. Though most people think the issues are unrelated, one potential way to decrease identity theft and preparer fraud is tax simplification.

Regs. Clarify Employment Tax Responsibilities of Designated Payer Agents

Final regulations issued by the IRS contain rules on the liability for employment taxes when an employer designates an agent under a “service agreement” to pay its employees and to satisfy its employment tax obligations instead of following normal IRS procedures to designate an agent.