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US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

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US Tax Disputes

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Disaster Recovery: IRS May be Forced to Refund Interest and Penalties Which Accrued During COVID-19

By Gregory Rhodes, Sidney Jackson, and Emily Ellis
  • General
  • IRS

When “Neither Snow Nor Rain” Is the Problem—It’s the Postmark

By Michelle Levin and Carneil Wilson
  • General
  • IRS

Form Over Function: Sirius Solutions and the Fifth Circuit’s Reversal of the Tax Court on Self-Employment Tax Exception for “Limited Partners”

By Ross Cohen, Helen Cooper, Caitlin Rieser, and Lucy McAfee
  • General
  • IRS

Key Federal Tax Updates Shaping 2026

By Mark A. Loyd, Gregory Rhodes, Helen Cooper, Sidney Jackson, and Lucy McAfee
  • General
  • IRS

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

By Michelle Levin, Sarah Green, and Olla Jaraysi
  • General
  • IRS
  • Transfer Pricing

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

By Michelle Levin, Logan Abernathy, and Emily Ellis
  • General
  • State and Local Taxation

Pennsylvania Tax Developments: Fall 2025

By Frank Marano
  • General
  • State and Local Taxation

Indiana Tax Developments:  Fall 2025

By Bradley Hasler, Jeffrey T. Bennett, Lucy McAfee, Mark A. Loyd, and Stephanie Bruns
  • General
  • State and Local Taxation

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
  • General
  • Legislation

The One Big Beautiful Bill Expands Code Section 1202 Gain Exclusion

By Ross Cohen, Caitlin Rieser, and Lucy McAfee

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