Tax News

CCH (cch.taxgroup.com) reports:

  The government properly withheld documents responsive to a corporation's Freedom of Information Act (FOIA) request because they were protected by attorney work-product privilege. However, the IRS was required to segregate and disclose the factual portions of documents withheld under the deliberative process privilege. Therefore, the IRS was required to submit affidavits detailing the withheld portions of documents to enable the district court and the corporation to evaluate the government's claims of exemption. Moreover, the district court was required to conduct an in camera review of the documents if sufficiently specific affidavits were not provided. Further, the district court's decision that the IRS properly applied the tax convention information exemption was remanded because the decision was made without the benefit of thorough briefing by the parties.

  Affirming in part, reversing and remanding in part in part a DC Wash. decision, 2006-2 USTC ¶50,607.

Pacific Fisheries Inc., CA-9, 2008-2 USTC ¶50,510

Other References:

 
Code Sec. 6103

  CCH Reference - 2008FED ¶36,894.802

  CCH Reference - 2008FED ¶36,894.8046

  CCH Reference - 2008FED ¶36,894.825

  Tax Research Consultant

  CCH Reference - TRC IRS: 9,502
CCH Reference - TRC IRS: 9,502.15
CCH Reference -
TRC IRS: 9,550
 

CCH (cch.taxgroup.com) reports:

  The General Services Administration (GSA) has updated the maximum per diem rates for locations within the continental United States (CONUS). The list increases or decreases the maximum lodging and meals and incidental expenses amounts in certain existing per diem localities, adds new per diem localities and removes some previously designated per diem localities. The list is effective for fiscal year (FY) 2009.

  The Governmentwide Per Diem Advisory Board was established in May 2002 by the GSA in order to review the federal per diem rate setting process and the governmentwide lodging program. Effective for FY 2009, the standard CONUS lodging rate is $70.

Maximum Per Diem Rates for Continental U.S.

Other References:

 
Code Sec. 274

  CCH Reference - 2008FED ¶14,417.421

Tax Analysts report:

CCH (cch.taxgroup.com) reports:

  A regulation has been adopted that explains the application of Illinois retailers' occupation (sales) tax, service occupation tax, and use tax to seminar materials. "Seminar materials" mean educational or informational material and any other item prepared, compiled, or obtained for distribution to seminar customers, such as books, practice guides, tapes, and compact discs. "Seminar" means any presentation, conference, training program, or continuing education course designed for educational, informational, professional, or recreational purposes.

CCH (cch.taxgroup.com) reports:

  An IRS Appeals Officer correctly concluded that the ten-year statute of limitations on collection of an individual's unpaid Federal income tax liabilities did not expire before the IRS filed its notice of Federal tax lien. Prior to expiration of the limitations period, the taxpayer agreed to extend the period for collection until December 31, 2011. Although the taxpayer asserted that the extension only applied to employment taxes, the Form 900, Tax Collection Waiver, signed by the taxpayer in connection with a defaulted installment agreement, clearly showed that the unpaid tax liabilities related to Form 1040 individual income tax liabilities.

H. Joy, TC Memo. 2008-197, Dec. 57,518(M)

Other References:

 
Code Sec. 6330

  CCH Reference - 2008FED ¶38,184.63

 
Code Sec. 6502

  CCH Reference - 2008FED ¶39,020.65

  Tax Research Consultant

  CCH Reference - TRC IRS: 45,204.25

  CCH Reference - TRC IRS: 48,056.25