Federal
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February 06, 2026
Steel Co. Founder's Estate Disputes $100M Deficiency
The estate of a Michigan steel company founder is challenging a deficiency of over $100 million assessed for 2022 from the Internal Revenue Service's increased valuation of the company's stock, according to a petition filed in the U.S. Tax Court.
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February 06, 2026
Buchanan Ingersoll Adds Two Veteran Tax Pros In DC
Buchanan Ingersoll & Rooney PC has expanded its tax offerings in the nation's capital with two attorneys, including the former co-chair of the tax and private wealth practice at Whiteford Taylor & Preston LLP.
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February 06, 2026
Gunster Brings On Longtime Tax Law Professor In Florida
Florida business law firm Gunster has added an experienced tax law professor to its ranks as of counsel.
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February 06, 2026
Taxation With Representation: Gibson Dunn, S&C, Wachtell
In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence startup xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.
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February 06, 2026
Trump's $10B Tax Leak Suit Legally Unsound, Ex-Officials Say
The $10 billion in damages President Donald Trump is seeking in his suit accusing the Internal Revenue Service of failing to prevent a former contractor from leaking Trump's tax returns to news outlets are legally unsupported and unprecedented, four former government officials told a Miami federal court.
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February 06, 2026
CPAs Suggest Treasury Scrap Doc Plans For CFC Rules
The U.S. Treasury Department should rethink planned documentation requirements for overseas income allocations, the American Institute of Certified Public Accountants recommended in a letter released Friday, saying the rules may be unnecessarily burdensome.
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February 06, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included an extension of the deadline for making amendments to individual retirement arrangements by another year.
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February 06, 2026
Tax Break Owed For $5.8M Power Plant Gift, Court Told
A partnership's donation of a $5.8 million biomass power plant to a North Carolina nonprofit should have triggered a tax break, the partnership told the U.S. Tax Court in challenging a denial by the Internal Revenue Service.
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February 05, 2026
NY Times Article Excerpts Admitted In Goldstein Trial
Federal prosecutors pressing their case against SCOTUSblog co-founder Thomas Goldstein for tax evasion and misleading statements on mortgage applications were finally able on Thursday to present jurors with key statements the U.S. Supreme Court lawyer made to legal journalist Jeffrey Toobin for a long New York Times Magazine article.
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February 05, 2026
Porn-Addiction Therapy Site Wins Deductions From Tax Court
A Maine couple held a for-profit motive with respect to a 47.71-acre plot of land but not a 3.89-acre plot, the U.S. Tax Court said in a decision Thursday, ruling that only some of the expenses incurred by the couple related to various businesses can be deducted.
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February 05, 2026
IRS Met Requirements To Impose Penalties, Tax Court Affirms
The Internal Revenue Service satisfied the supervisory approval requirements to impose penalties after disallowing a Missouri-based company's conservation easement deduction for the 2019 tax year, the U.S. Tax Court affirmed Thursday.
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February 05, 2026
Dispensary Co. Can't Get Worker Tax Credit, Court Says
An operator of California marijuana dispensaries is ineligible for a federal tax credit meant to help businesses weather the COVID-19 pandemic because of a bar on tax breaks for businesses that sell controlled substances, the U.S. Court of Federal Claims said.
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February 05, 2026
Trump Admin Finalizes Rule Facilitating Federal Worker Firings
The Trump administration Thursday announced a final rule to create a new category of federal workers who would have fewer job protections and be easier to fire, implementing an executive order from early last year that could affect 50,000 employees at federal agencies.
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February 05, 2026
Ga. Law Firm's CTA Challenge 'Hypothetical,' Feds Argue
The U.S. Treasury Department has asked a federal judge to toss a Georgia lawyer's suit alleging that the 2021 Corporate Transparency Act could force him to violate attorney-client privilege, arguing the suit is based on future "hypothetical changes" to the federal policy of nonenforcement.
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February 05, 2026
Hostages Aren't Receiving Tax Relief, TIGTA Says
Recently released hostages did not receive tax relief despite the Internal Revenue Service implementing new procedures to improve the process to provide tax relief to taxpayers wrongfully detained or taken hostage, the Treasury Inspector General for Tax Administration said in a report released Thursday.
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February 04, 2026
Goldstein Accountant Admits Tax Return Errors
A star government witness and the top outside accountant for SCOTUSblog founder Thomas Goldstein and his law firm admitted to making mistakes on Goldstein's tax returns and offering the grand jury erroneous testimony, under cross-examination in the U.S. Supreme Court lawyer's tax fraud trial Wednesday.
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February 04, 2026
US House Votes To Overturn DC Tax Code Changes
A Washington, D.C., local law that uncouples elements of the city's tax code from federal tax law would be repealed under a resolution passed in the U.S. House of Representatives on Wednesday.
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February 04, 2026
Dem Sens. Press Treasury, AG Over $10B Trump Tax Leak Suit
Two Senate Finance Committee Democrats pressed Treasury Secretary Scott Bessent and Attorney General Pam Bondi on whether Treasury was working with President Donald Trump to secure him a settlement in his $10 billion taxpayer privacy lawsuit against the IRS, according to a letter released Wednesday.
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February 04, 2026
Trump Bid To Move NY Appeal Faces 'Fatal' Error, Judge Says
A Manhattan federal judge on Wednesday repeatedly aired doubts that President Donald Trump can upend the pending New York state appeal of his hush-money conviction by moving the case to federal court.
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February 04, 2026
Tax Group Of The Year: Davis Polk
Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.
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February 04, 2026
Tax Court Urged To Restore $43M Break For Historic Buildings
A partnership argued for restoring its $43 million tax deduction for protecting historic property in Kentucky that included a 19th century post office, telling the U.S. Tax Court that the IRS had arbitrarily rejected its claim.
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February 04, 2026
IRS Urges Tax Court To Cut $315M From Siemens Deduction
The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.
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February 04, 2026
Walmart Wants Relief In CFC Tax Year Deferral
Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.
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February 03, 2026
Goldstein Knew What Was On His Returns, Accountant Claims
The top outside accountant handling tax returns for SCOTUSblog founder Thomas Goldstein and his law firm said Tuesday that Goldstein wasn't forthcoming about his gambling records and that he firmly believed the former U.S. Supreme Court attorney knew what was in his allegedly false tax returns when they were filed.
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February 03, 2026
Tax Court Allows Some Credits For Co.'s Chicken Research
The owner of a poultry processing business is entitled to some of the tax credits he claimed for his company's chicken research, the U.S. Tax Court ruled Tuesday, disagreeing with the Internal Revenue Service's position that the work was routine and ineligible for a tax break.
1st Circ. Probes Jurisdiction In Partner Employment Tax Case
First Circuit judges grappled Thursday with whether an energy investment fund's limited partners should be exempt from the self-employment tax, with much of the argument in the closely watched case focused on whether the U.S. Tax Court had the authority to make the decision in the first place.
5 Takeaways From 5th Circ.'s Limited Partner Tax Decision
The Fifth Circuit has issued a long-awaited opinion holding that partners with limited liability under state law qualify for an exclusion from the self-employment tax, and the decision offers five notable takeaways that experts said may shed light on the potential fate of partnership taxation and compliance.
IRS Floats Clean Fuel Credit Rules With Foreign Restrictions
The Internal Revenue Service released long-awaited proposed regulations Tuesday clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by Republicans' 2025 budget law, including new foreign restrictions on business owners and feedstock sources.
Featured Stories
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5 Takeaways From 5th Circ.'s Limited Partner Tax Decision
The Fifth Circuit has issued a long-awaited opinion holding that partners with limited liability under state law qualify for an exclusion from the self-employment tax, and the decision offers five notable takeaways that experts said may shed light on the potential fate of partnership taxation and compliance.
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The Tax Angle: Congressional Taxwriters Head For The Exits
This edition of The Tax Angle examines upcoming retirements among members of the Senate Finance and House Ways and Means committees ahead of the midterm elections this November.
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3 Things To Keep In Mind About IRS' Corporate Audit Changes
The IRS' revamped audit process for corporate taxpayers will likely streamline examinations, but companies may now shoulder new responsibilities when presenting facts and face lingering uncertainties when weighing whether to participate in a broadened settlement program. Here, Law360 examines three key issues for companies to consider under the new audit process.
Expert Analysis
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Where PCAOB Goes Next After A Year Of Uncertainty
The Public Company Accounting Oversight Board will likely bring fewer enforcement matters in 2026, reflecting a notable change in board priorities following the change in administrations, say Robert Cox and Nicole Byrd at Whiteford Taylor and Matthew Rogers at Bridgehaven Consulting.
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5th Circ. Ruling Clarifies Tax Rules For Limited Partners
The Fifth Circuit’s Jan. 16 decision in Sirius Solutions v. Commissioner provides greater tax planning certainty by adopting a bright-line test for determining when partners in limited liability companies are exempt from self-employment tax, say attorneys at K&L Gates.
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NYC Bar Opinion Warns Attys On Use Of AI Recording Tools
Attorneys who use artificial intelligence tools to record, transcribe and summarize conversations with clients should heed the New York City Bar Association’s recent opinion addressing the legal and ethical risks posed by such tools, and follow several best practices to avoid violating the Rules of Professional Conduct, say attorneys at Smith Gambrell.
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4 Quick Emotional Resets For Lawyers With Conflict Fatigue
Though the emotional wear and tear of legal work can trap attorneys in conflict fatigue — leaving them unable to shake off tense interactions or return to a calm baseline — simple therapeutic techniques for resetting the nervous system can help break the cycle, says Chantel Cohen at CWC Coaching & Therapy.
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Rescheduling Cannabis Marks New Tax Era For Operators
As the attorney general takes steps to move cannabis from Schedule I to Schedule III of the Controlled Substances Act, operators and advisers should prepare by considering the significant changes this will bring from tax, state, industry and market perspectives, says Michael Harlow at CohnReznick.
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Judges On AI: How Judicial Use Informs Guardrails
U.S. Magistrate Judge Maritza Dominguez Braswell at the U.S. District Court for the District of Colorado discusses why having a sense of how generative AI tools behave, where they add value, where they introduce risk and how they are reshaping the practice of law is key for today's judges.
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Presidential Pardon Brokering Can Create Risks For Attys
The emergence of an apparent “pardon shopping” marketplace, in which attorneys treat presidential pardons as a market product, may invite investigative scrutiny of counsel and potential criminal charges grounded in bribery, wire fraud and other statutes, says David Klasing at The Tax Law Offices of David W. Klasing.
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Key False Claims Act Trends From The Last Year
The False Claims Act remains a powerful enforcement tool after some record verdicts and settlements in 2025, and while traditional fraud areas remain a priority, new initiatives are raising questions about its expanding application, says Veronica Nannis at Joseph Greenwald.
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Hosting Exchange Students Makes Me A Better Lawyer
Opening my home to foreign exchange students makes me a better lawyer not just because prioritizing visiting high schoolers forces me to hone my organization and time management skills but also because sharing the study-abroad experience with newcomers and locals reconnects me to my community, says Alison Lippa at Nicolaides Fink.
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How A 1947 Tugboat Ruling May Shape Work Product In AI Era
Rapid advances in generative artificial intelligence test work-product principles first articulated in the U.S. Supreme Court’s nearly 80-year-old Hickman v. Taylor decision, as courts and ethics bodies confront whether disclosure of attorneys’ AI prompts and outputs would reveal their thought processes, say Larry Silver and Sasha Burton at Langsam Stevens.
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Navigating Privilege Law Patchwork In Dual-Purpose Comms
Three years after the U.S. Supreme Court declined to resolve a circuit split in In re: Grand Jury, federal courts remain split as to when attorney-client privilege applies to dual-purpose legal and business communications, and understanding the fragmented landscape is essential for managing risks, say attorneys at Covington.
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Cannabis Industry Faces An Inflection Point This Year
Cannabis industry developments last year — from the passage of a new wholesale tax in Michigan, to an executive order accelerating the federal rescheduling process — presage a more mature phase of legalization this year, with hardening expectations and enforcement to come, says Alex Leonowicz at Howard & Howard.
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.