General IRS 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 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
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
IRS Planning for taxes on personal injury judgments By Stephanie Bruns, Helen Cooper, Mark A. Loyd, and Lucy McAfee
General IRS IRS AOD 2024‑01: Relief for Taxpayers Facing § 6707A Penalties By Gregory Rhodes, Mark A. Loyd, Sidney Jackson, Helen Cooper, and Benjamin Strong
