US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

Whose Fraud is it Anyway? – Third Circuit Says Anyone’s Will Do!

By Michelle Levin, Ronald Levitt, Sarah Green, and Olla Jaraysi

August 28, 2025

General
IRS

Latest Posts

General
IRS

Second Circuit Decision Confirms Taxpayers May Still Be Able to Challenge Deficiencies Even if They Miss the Filing Deadline

By Michelle Levin, Sarah Green, and Ryder Winborn

State and Local Taxation

Key Lessons In Appealing Kentucky Property Tax Assessments

By Mark A. Loyd, Stephanie Bruns, and Lucy McAfee

State and Local Taxation

Equal Protection for Kentucky Real Property Taxes

By Mark A. Loyd, Bailey Roese, and Stephanie Bruns

The One Big Beautiful Bill Expands Code Section 1202 Gain Exclusion

By Ross Cohen, Caitlin Rieser, and Lucy McAfee

IRS

Functional Analysis Over Formalism: Soroban and the SECA Exception for Passive Limited Partners

By Ross Cohen, Stephanie Bruns, Caitlin Rieser, and Lucy McAfee

IRS

Tax-Efficient Ways to Structure Fund Manager Compensation

By Ross Cohen, Caitlin Rieser, and Lucy McAfee

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