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06.13.2025

Firm Publication

Novel Tax Court Interpretation of Section 461(h) Economic Performance Requirement

Tax Alert

06.13.2025

Firm Publication

IRS Notches Another Win Over the Limited Partner Exception to Self-Employment Tax

Tax Alert

06.13.2025

Firm Publication

Tax Court Issues Split Ruling in Facebook

Tax Alert

05.13.2025

Firm Publication

The Reportable Transaction Retreat Has Begun… Where Will it End?

Tax Alert

05.13.2025

Firm Publication

Collateral Issues Dominate in Final Briefing for Varian and Sysco

Tax Alert

05.13.2025

Firm Publication

The Growing Impact of Loper Bright on the Tax Court

Tax Alert

05.02.2025

External Publication

Administration Order to Rescind Guidance Raises Questions Under the APA

03.12.2025

Firm Publication

Administrative Actions Subject to Renewed Scrutiny Under New Executive Orders

Tax Alert

03.12.2025

Firm Publication

Suspended Losses Preclude Tax Court from Hearing Accounting Method Change Dispute

Tax Alert

03.12.2025

Firm Publication

District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ

Tax Alert

02.13.2025

Firm Publication

IRS Announces ADR Pilot Programs

Tax Alert

02.13.2025

Firm Publication

Taxpayer Access to Appeals Remains Constrained Under Final Section 7803 Regulations

Tax Alert

01.16.2025

Firm Publication

Treasury Publishes Final Regulations for Supervisory Approval of Penalties

Tax Alert

01.16.2025

Firm Publication

Bruyea Confirms Treaty-Based Foreign Tax Credits for the NIIT

Tax Alert

01.16.2025

Firm Publication

Tax Court Rejects IRS Inventory Argument in Easement Case

Tax Alert

01.16.2025

Firm Publication

Employee Retention Credits Continue to Be a Sore Spot for Taxpayers and the IRS

Tax Alert

01.16.2025

Firm Publication

Tax Court Grants Bloomberg a Win on Section 199 Online Software Claim

Tax Alert

12.12.2024

Firm Publication

Tax Court Again Holds IRS Lacks Authority to Assess Foreign Reporting Penalty

Tax Alert

11.04.2024

Firm Publication

IRS and Treasury Issue Final Syndicated Conservation Easement Regulations

Tax Alert

10.07.2024

Firm Publication

Tax Court Requests Amicus Briefs on ESD in Patel

Tax Alert

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publications

Novel Tax Court Interpretation of Section 461(h) Economic Performance Requirement

IRS Notches Another Win Over the Limited Partner Exception to Self-Employment Tax

Tax Court Issues Split Ruling in Facebook

The Reportable Transaction Retreat Has Begun… Where Will it End?

Collateral Issues Dominate in Final Briefing for Varian and Sysco

The Growing Impact of Loper Bright on the Tax Court

Administration Order to Rescind Guidance Raises Questions Under the APA

Administrative Actions Subject to Renewed Scrutiny Under New Executive Orders

Suspended Losses Preclude Tax Court from Hearing Accounting Method Change Dispute

District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ

IRS Announces ADR Pilot Programs

Taxpayer Access to Appeals Remains Constrained Under Final Section 7803 Regulations

Treasury Publishes Final Regulations for Supervisory Approval of Penalties

Bruyea Confirms Treaty-Based Foreign Tax Credits for the NIIT

Tax Court Rejects IRS Inventory Argument in Easement Case

Employee Retention Credits Continue to Be a Sore Spot for Taxpayers and the IRS

Tax Court Grants Bloomberg a Win on Section 199 Online Software Claim

Tax Court Again Holds IRS Lacks Authority to Assess Foreign Reporting Penalty

IRS and Treasury Issue Final Syndicated Conservation Easement Regulations

Tax Court Requests Amicus Briefs on ESD in Patel

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