HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

SPECIAL ANNOUNCEMENT

Announcement 2007–106, page 1021. The announcement for the 2008 IRS Individual e-file Partnership Program will solicit applications from potential partners for participation in the program. The partnership opportunities are a result of RRA 98, which authorized the IRS Commissioner to promote the benefits of and encourage the use of e-file products and services through partnerships with various entities that offer low-cost tax preparation and electronic filing of individual income tax returns for qualified taxpayers. Those applicants that are accepted into the program will have a link(s) and offer description(s) for their products and services posted to IRS.gov (Partners Page).

INCOME TAX

Ct. D. 2083, page 986. Levies upon third party property to collect taxes owed by another; wrongful levy action. The Supreme Court holds that the Trust missed section 7426(a)(1)’s deadline for challenging a levy, and may not bring the challenge as a tax refund claim under section 1346(a)(1).

REG–140206–06, page 1006. Proposed regulations under section 1441 of the Code provide guidance regarding the withholding and reporting obligations of a withholding agent in the case of a self tender by a publicly traded corporation, when a determination is required under section 301 as to whether the distribution is treated as a dividend or a distribution in part or full payment in exchange for stock. A public hearing is scheduled for February 6, 2008.