Blog - US Tax Disputes

US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

General
IRS

Juries, Penalties, and Timing: Post-Jarkesy Fault Lines of IRS Assessments

By Michelle Levin, Sarah Green, and Olla Jaraysi

Another [Treasury Regulation] Bites the Dust, Part 1 of 4

By Michelle Levin, Logan Abernathy, and Emily Ellis

Pennsylvania Tax Developments: Fall 2025

By Frank Marano

Indiana Tax Developments: Fall 2025

By Bradley Hasler, Jeffrey T. Bennett, Lucy McAfee, Mark A. Loyd, and Stephanie Bruns

Kentucky Tax Developments: Fall 2025

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

General
IRS

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

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

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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