Federal
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September 23, 2026
Home Health Co. Asks Tax Court To Invalidate IRS Levy
An in-home health company is not liable for nearly $236,000 in civil penalties imposed by the Internal Revenue Service, it told the U.S. Tax Court, urging it to determine that the agency's proposed levy action should not have been sustained.
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September 23, 2026
Aventis Denies Owning Assets In $40M Tax Fight At 3rd Circ.
The U.S. Tax Court contradicted its own findings by deciding that pharmaceutical company Aventis controlled assets in an investment vehicle with a French affiliate, couldn't deduct related payments and was liable for nearly $40 million in income taxes, the company told the Third Circuit.
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September 23, 2026
Judge Dismisses Son's Bid To Recoup Parents' Tax Payments
A Tennessee federal judge dismissed a son's bid for a refund of federal income taxes for his dead parents' estates, finding he failed to establish that his father sufficiently participated in an amusement equipment manufacturing business to claim associated losses.
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September 22, 2026
IRS Requests Comments On Proposed Opportunity Zone Regs
The Internal Revenue Service on Tuesday requested comments on the implementation of the federal opportunity zone program, including whether additional guidance is needed to address issues related to opportunity fund investment.
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September 22, 2026
Atty Urges 4th Circ. To Reverse Liability For Client's Taxes
A Baltimore attorney asked the Fourth Circuit to reverse a lower court's order that he cover unpaid federal income taxes owed by his client's holding company, saying he didn't engage in self-dealing.
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September 22, 2026
8th Circ. Asked To Nix Fraud Tax Credit Suit, $90M Judgment
A man accused of helping form a sham limited liability company that fraudulently received millions in alternative fuel mixture tax credits asked the Eighth Circuit on Tuesday to reverse a judgment of more than $90 million against him, saying he shouldn't be personally liable for the company's conduct.
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September 22, 2026
US Asks 5th Circ. To Revive IRS Deal On Church Politicking
The U.S. government urged the Fifth Circuit to revive its deal with four religious groups to allow churches to engage in some political speech without losing their tax-exempt status, saying a lower court improperly dismissed the case in its entirety for lack of jurisdiction.
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September 22, 2026
Tax Court OKs $21M Easement Cut In Appeal Process Fight
The IRS did not wrongfully deny a holding company the chance to appeal a reevaluation that lopped $21 million off the value of a Tennessee conservation easement for which it claimed a deduction, the U.S. Tax Court ruled Tuesday.
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September 22, 2026
Dispensary's Tax Deduction Properly Nixed, IRS Tells 9th Circ.
The U.S. Tax Court correctly ruled that a San Francisco marijuana dispensary's expenses found to be tied to trafficking in controlled substances aren't deductible, the IRS told the Ninth Circuit, saying such a deduction shouldn't be allowed in determining an amount to settle the business's $3 million tax debt.
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September 22, 2026
Virgin Islands Tax Agency Can't Ignore Treasury, Judge Says
The U.S. Supreme Court's 2024 Loper Bright decision does not allow U.S. Virgin Islands revenue collectors to override U.S. Treasury Department regulations exempting residents of the territory from the net investment income tax, a federal judge held.
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September 21, 2026
Xbox Buyer Says IEEPA Refund Arbitration Bid Lacks Backing
Microsoft's bid to force arbitration of an Xbox purchaser's proposed class action accusing the video game giant of wrongfully withholding tariff refunds from consumers should fail because it can't point to a clause that covers his dispute, he told a Washington federal court.
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September 21, 2026
IRS Properly Nixed Tax Deals, Couple Owe $1.8M, Judge Says
A disbarred lawyer and his wife owe more than $1.8 million in outstanding tax liabilities the IRS has tried to collect for more than a decade, a Wisconsin federal judge said, finding the agency substantiated the liabilities and confirmed that it properly rescinded compromise offers to resolve the debts.
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September 21, 2026
Partnership Was Diligent After Notice Got Lost, Court Says
A partnership's late-filed petition in the U.S. Tax Court was due to circumstances beyond its control in a case where the final partnership adjustment from the IRS was mailed correctly but returned by the U.S. Postal Service as undeliverable, the court held Monday.
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September 21, 2026
IRS Can Enforce Summons In Korean Probe Of VC Partner
The IRS can enforce a summons seeking bank information about a venture capitalist on behalf of South Korean tax authorities, a California federal judge ruled, holding that the statutory requirement to provide advance notice applies only to domestic tax liabilities.
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September 21, 2026
IRS Again Delaying Dividend Anti-Abuse Regs
The IRS is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, the agency announced Monday.
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September 21, 2026
IRS' Economic Substance Doctrine Has Limits, 5th Circ. Told
The IRS should not invoke the economic substance doctrine whenever it dislikes a transaction's tax consequences, an advocacy group told the Fifth Circuit on Monday in an eye doctor and his wife's appeal of a ruling that rejected their ophthalmology practice's microcaptive insurance arrangements.
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September 21, 2026
Varian, Gov't Appeal Foreign Dividend Decision To 9th Circ.
Varian Medical Systems Inc. is appealing a U.S. Tax Court decision that it owes more than $7.2 million to the Internal Revenue Service as a result of the court limiting its deemed dividends deduction, while the government is also appealing, according to filings in the Ninth Circuit.
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September 21, 2026
IRS Asks 5th Circ. To Pause Microcaptive Rules Case
The IRS asked the Fifth Circuit to stay briefing in a global tax services provider's bid to revive its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a related case before the appeals court.
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September 21, 2026
Funder Says $13M Albania Default Judgment Should Stand
Litigation funder Omni Bridgeway has urged a D.C. federal court to preserve a default judgment enforcing a roughly $13 million arbitral award against Albanian state entities, arguing they waited an unreasonable 18 months to appear despite receiving repeated notice of the case.
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September 18, 2026
Ex-DOJ Chief Lambastes 'Abuses Of Power' In Goldstein Case
The U.S. Department of Justice constantly made false statements in its criminal case against famed appellate advocate Tom Goldstein, and his convictions must be erased because "prosecutorial misconduct pervaded every stage of the proceedings," a former DOJ prosecutor told the Fourth Circuit.
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September 18, 2026
Judge Questions Whether 'Lawfare' Fund Fight Is Really Moot
A Virginia federal judge seemed unlikely to toss a challenge to the Trump administration's nixed "Anti-Weaponization Fund" and tax audit immunity for the Trump family Friday, saying she worries the fund could be revived in a different form down the road.
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September 18, 2026
US Asks Fed. Circ. To Reverse COVID-Era Tax Deadline Ruling
The government asked the Federal Circuit to overturn a U.S. Court of Federal Claims decision allowing a taxpayer to recover penalties and interest he sought refunds for during the COVID-19 pandemic, saying the claims court wrongly interpreted a statutory 60-day extension as having lasted over three and a half years.
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September 18, 2026
Exxon Wins $456M Tax, Penalty Refund In Qatar Gas Case
Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.
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September 18, 2026
House Bill Would Limit BEAT, Make Other Int'l Tax Changes
The U.S. would limit the scope of its base erosion and anti-abuse tax and modify several other international tax measures under a bill introduced by a Republican on the House Ways and Means Committee.
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September 18, 2026
IRS Security Program 'Not Effective' In 2026, TIGTA Says
Facets of the IRS' cybersecurity program have improved since last year but are still ultimately "not effective," the Treasury Inspector General for Tax Administration said Friday, finding the deficiencies may leave taxpayer data vulnerable.
Expert Analysis
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4 Emerging Approaches To AI Protective Order Language
Over the last year, at least five federal district courts have issued or analyzed specific protective order provisions restricting the use of generative artificial intelligence platforms with protected materials, establishing that proactive AI-specific provisions are now standard practice and demonstrating that no single model works for every case, says Joel Bush at Kilpatrick.
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Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved
While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady.
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How To Limit Accounting Fraud Risk As SEC Focus Persists
Despite the U.S. Securities and Exchange Commission's pullback on crypto, cybersecurity and recordkeeping cases, accounting fraud remains a core enforcement priority, making it important for public companies and auditors to strengthen controls, investigations and whistleblower processes, say attorneys at Pillsbury.
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Speed Jigsaw Puzzling Makes Me A Better Lawyer
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the ability to keep the bigger picture in mind while working through the details, says Tazia Statucki at Proskauer.
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Documenting Business Purpose After IRS' 10th Circ. Win
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audits by maintaining contemporaneous documentation and taking other steps that demonstrate the business purpose of transactions, say attorneys at Crowell & Moring.
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2 AI Snafus Show Why Attys Can't Outsource Judgment
The recent incident involving Sullivan & Cromwell where citations in a filed motion were fabricated by artificial intelligence, as well as a punitive ruling from the Sixth Circuit in U.S. v. Farris, demonstrate that the obligation to supervise AI has belonged and always will belong to lawyers, says John Powell at the Kentucky School Boards Association.
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How Data Center Accounting May Draw Enforcement Scrutiny
As public and media scrutiny of the data center industry intensifies, regulators, enforcement authorities and Congress will likely focus on accounting judgments that rely on aggressive assumptions, opaque financing structures or rapidly evolving collateral classes, heightening the risk of investigations and inquiries, say attorneys at King & Spalding.
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Improving Well-Being In Law, 10 Years After Landmark Study
An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.
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How To Gear Up For Trump's Pharma Tariffs
President Donald Trump's proclamation establishing tariffs on certain pharmaceutical products holds a few areas of ambiguity that companies should review and prepare for before the tariffs come into effect later this year, say attorneys at Arnold & Porter.
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Steps To Consider As DOJ Launches Fraud Division
The establishment this month of the National Fraud Enforcement Division within the U.S. Department of Justice is a significant reorganization that suggests an increase in enforcement activity involving federally funded programs but leaves a number of important questions unanswered, say attorneys at Crowell & Moring.
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What To Expect From The SEC's New SOX Group
In a potential shift away from Public Company Accounting Oversight Board enforcement, the U.S. Securities and Exchange Commission's formation of a new group to investigate and litigate potential violations of the Sarbanes-Oxley Act brings both risks and benefits for auditors, say attorneys at King & Spalding.
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Hungary CPAC Funding Probe Could Implicate US Entities
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.
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Mitigating Multistate Risks As California Expands Tax Reach
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.