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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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D.C. Circuit Affirms the Importance of Filling Out Form 8283 Completely

By Jeff Erney
  • General
  • IRS
  • Litigation

Denver-Based Court of Appeals Issues Two Important Cannabis Rulings

By Jeff Erney
  • Litigation
  • State and Local Taxation

A Split U.S. Supreme Court Abandoned 50 Years of Precedent and Holds States Can Tax Internet Companies

By Jeff Erney
  • IRS
  • IRS Administration
  • Litigation

Eleventh Circuit Holds that Taxpayer’s Affidavit Can Defeat Summary Judgment

By Jeff Erney
  • Circular 230 and Ethical Issues
  • Estate and Gift Tax
  • IRS
  • Litigation

Tax Court Disallows a $33 Million Charitable Donation Deduction Because Taxpayer Did Not Sufficiently Fill Out Form

By Jeff Erney
  • IRS
  • IRS Administration
  • Litigation
  • Tax Crimes

Supreme Court Agrees to Review Sweeping Tax Obstruction of Justice Decision

By Jeff Erney
  • Individual Taxation
  • IRS Examination Process
  • Litigation
  • Refund Claims

The Ninth Circuit Holds Equitable Recoupment Not Time-Barred

By Marc Teitelbaum and John Harrington
  • IRS Administration
  • Litigation
  • Refund Claims

Sixth Circuit Sharpens Ford’s Focus on Payment of Overpayment Interest

By Ryan Zucchetto
  • Litigation
  • Refund Claims

SCOTUS Vacates and Remands Ford Decision to Determine Proper Jurisdiction

By Ryan Zucchetto
  • IRS Administration
  • Litigation
  • Refund Claims

Ford Attempts to Catch the Ear of SCOTUS in Pursuit of Approximately $470 Million

By Ryan Zucchetto
  • IRS Examination Process
  • Litigation
  • Tax Crimes

“Strategies for Managing Parallel Proceedings with Fifth Amendment Implications,” Inside the Minds: Strategies for Criminal Tax Cases

By Marc Teitelbaum and John Harrington
  • IRS Administration
  • Litigation

Qualified Offers and the Recovery of Administrative and Litigation Costs from the IRS

By Marc Teitelbaum and John Harrington

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Additional resources

Visit our Global tax guide to doing business in... 2022.

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