Focus on Tax Controversy and Litigation - New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection of Taxes Relating to Partnership Activities

A&O Shearman
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In addition to the discussion of the new partnership audit rules, this month’s issue features articles regarding a recent district court decision in Ellis v. United States regarding the attorney-client privilege and work product protections, amendments to the Federal Rules of Civil Procedure, recent developments concerning the IRS’s enforcement efforts regarding offshore accounts and a discussion of the benefits and potential pitfalls of making a tax deposit.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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