Federal
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October 26, 2026
Appraiser Defends $37M Deduction For Texas Land Donations
A trial wrapped up Monday for two partnerships claiming a combined $37 million deduction for their donation of beachfront property in Texas after the U.S. Tax Court heard from witnesses, including an appraiser who challenged the government's position that the land was worth only $4.3 million.
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October 26, 2026
Gov't Urges 8th Circ. To Reconsider Tax Deadline Ruling
The government asked the Eighth Circuit on Monday to reconsider its finding that a 90-day petition-filing deadline is flexible in the case of a couple challenging their tax bill in the U.S. Tax Court, saying the ruling broadens a circuit split that prevents uniform administration of federal tax law.
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October 26, 2026
IRS Won't Defend Anti-Abuse Rule Invalidated By Tax Court
The IRS will no longer defend a rule designed to prevent companies from receiving tax-free dividends by exploiting a mismatch in effective dates between Tax Cuts and Jobs Act provisions after the U.S. Tax Court decided Congress hadn't granted authority to issue it, the agency said.
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October 26, 2026
IRS Faces Compliance, Data Security Challenges, TIGTA Says
The Internal Revenue Service faces seven major management and performance challenges, including protecting taxpayer data, ensuring tax compliance and implementing tax law changes, the Treasury Inspector General for Tax Administration said in a report Monday.
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October 26, 2026
IRS Asks Tax Court To Rethink Allowing Late Easement Case
The U.S. Tax Court wrongly excused the lateness of a conservation easement partnership case based on a misinterpretation of a deadline provision in a statute governing judicial review of partnerships, the IRS argued in a bid to revisit a September opinion.
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October 26, 2026
Ex-Pa. Senator Wrongly Convicted Over Tax, 3rd Circ. Told
The U.S. Tax Court erred when it found a former Pennsylvania state senator responsible for losses to the state's Senate, he told the Third Circuit, arguing that the lower court incorrectly determined that excess compensation paid to employees constituted income to him.
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October 26, 2026
NC Top Court Will Weigh State Bar's Reach Over Ex-Judges
The North Carolina Supreme Court agreed to take up a former state court judge's appeal challenging the state bar's authority to discipline him for alleged misconduct on the bench, which he said the Tar Heel state's judicial oversight board had already addressed.
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October 26, 2026
Former Willkie Partner, Wife Owe $14.5M Tax Debt, Gov't Says
A former Willkie Farr & Gallagher LLP partner and his wife owe the U.S. more than $14.5 million in unpaid taxes, penalties and interest, according to a complaint filed in Manhattan federal court that seeks to enforce federal tax liens against their New York home to settle the debt.
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October 26, 2026
IRS FAQs Clarify Relief From Dyed Diesel Excise Tax
The Internal Revenue Service issued 11 FAQs addressing the recent interim relief from the dyed fuel excise tax, including the use of dyed biodiesel mixtures and reporting exemptions, for businesses and organizations using the fuel for on-road vehicles.
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October 23, 2026
IRS Fights For Microcaptive Reporting Rules In 5th Circuit
The Fifth Circuit should restore a vacated regulation that required disclosure of certain microcaptive transactions due to the risk of tax avoidance and uphold another related rule that carried a lower penalty for reporting failures, the government said Friday, arguing against a plastics manufacturer fighting to eliminate both.
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October 23, 2026
Virgin Islands NIIT Exemption Should Stay Intact, Court Told
A former U.S. Virgin Islands resident urged a federal court Friday not to rethink its decision holding that locals are exempt from the net investment income tax, arguing it's too late for the territory's revenue collectors to raise new arguments.
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October 23, 2026
Tax Court Misread Easement Rules, 4th Circ. Told
The U.S. Tax Court imposed conservation easement donation requirements beyond what the law allows in evaluating a property's condition and potential mining value, a partnership told the Fourth Circuit, seeking to overturn the 2025 denial of its charitable deduction.
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October 23, 2026
TIGTA Says 2.2M Returns Prepped By Noncompliant Preparers
More than 38,000 tax preparers with a noncompliant IRS identifier status prepared more than 2.2 million returns for processing in 2025, the Treasury Inspector General for Tax Administration said in a report assessing the agency's issuing, renewing and monitoring of the identifiers.
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October 23, 2026
Wyden Floats Data Center Excise Tax, Limits On Incentives
Data centers wouldn't be eligible for opportunity zone incentives and data center operators would be subject to an excise tax on gross receipts under draft legislation released Friday by the top Democrat on the Senate Finance Committee.
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October 23, 2026
Taxation With Representation: Milbank, De Brauw, Wachtell
In this week's Taxation With Representation, EQT Private Equity announces a takeover offer for life sciences testing company Qiagen NV, Salesforce acquires customer engagement platform Braze and London Stock Exchange Group buys U.S. credit intelligence provider Octus.
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October 23, 2026
Dutch Tax Treaty Policy Should Wait For Int'l Deal, NFTC Says
The Netherlands should not unilaterally change its tax treaty policy to allow countries to collect levies from remote corporations, the National Foreign Trade Council said Friday, urging the government to wait for countries to agree on new international norms.
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October 23, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included temporary rules on how to establish the tax-advantaged brokerage accounts for children known as Trump Accounts.
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October 22, 2026
Vegas Man Gets 38 Months For $5M Tax Refund Fraud Scheme
A Las Vegas man was sentenced to more than three years in prison for his role in what the government described as a $5 million tax refund fraud scheme that also involved his mother, who owned a tax preparation business, federal prosecutors said.
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October 22, 2026
IRS Says Tax Court Lacks Jurisdiction In Late-Filed Case
The U.S. Tax Court erred by finding it has jurisdiction in a partnership case that missed the 90-day window for filing its petition, the IRS said, arguing that relevant language in 2015 legislation is identical to that in prior legislation that mandated dismissing a similar case.
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October 22, 2026
Dems Seek GAO Review Of $166B Tariff Refund Operation
Democratic lawmakers serving in the U.S. House and Senate asked for the Government Accountability Office to evaluate Customs and Border Protection's administration of a tariff refund system designed to repay importers the $166 billion in paid duties deemed unlawful earlier this year by the U.S. Supreme Court, according to a Thursday news release.
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October 22, 2026
GOP Reps. Seek Probe Of Fla. Judge's Sanctions Order
Top Republicans on the House Judiciary Committee asked the Judicial Conference Thursday to investigate a Florida federal judge for potential misconduct with an order she issued in the case involving the leak of President Donald Trump's tax returns.
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October 22, 2026
5th Circ. Orders New Look At IRS' Loss On FBAR Jury Rights
A Texas federal court must revisit its 2025 ruling that the IRS violated a woman's jury-trial rights by imposing a $1 million civil penalty for failing to report foreign bank accounts, the Fifth Circuit said, ordering another review in light of a U.S. Supreme Court decision.
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October 22, 2026
UPS Waiting On Feds To Refund Tariff Costs, Court Told
An Atlanta federal court should, at minimum, pause a proposed class action looking to force UPS to reimburse customers for costs they incurred as the result of struck-down reciprocal tariffs, the shipping giant said, as the company itself is still waiting on refunds.
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October 22, 2026
Tax Court Scraps $75M Easement Deduction As 'Cartoonish'
The U.S. Tax Court refused to approve a partnership's $74.5 million charitable tax deduction for a Tennessee conservation easement Thursday, describing it as a "cartoonish" amount for a nearly $3 million property that sat on the market for years.
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October 22, 2026
IRS Creates New Retirement Plan Correction Program
The Internal Revenue Service issued two revenue procedures Thursday, including one creating a correction program for individual retirement accounts.
Expert Analysis
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A 3-Part Blueprint For Sentencing Variance Arguments
Tom Goldstein’s upcoming sentencing provides a useful lens for defense practitioners seeking a variance from the guidelines range, serving as a reminder to distinguish those requests from guidelines challenges and build an evidence-based case well before the hearing, says Joseph De Gregorio of Sentencing Advocacy Group.
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Mich. Banking Brief: All The Notable Legal Updates In Q2
The second quarter brought several notable financial services law developments to Michigan, including a U.S. Supreme Court ruling on state tax foreclosures, progress on a money transmission modernization bill package, and continued legislative momentum on cryptocurrency and mortgage lending, say attorneys at Dykema.
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Proof, Not Just Timing, Will Decide Clean Energy Credits
For wind and solar projects that sprinted to begin construction before the accelerated placed-in-service deadline of July 4, project owners must now assemble and maintain documentation to qualify the project and defend against a potential clean energy credit audit, says Peter Lowy at Nelson Mullins.
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Choral Singing Makes Me A Better Lawyer
Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.
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Tariff Refunds May Reshape Loan Covenant Calculations
Tariff refunds issued after the U.S. Supreme Court's Learning Resources decision may complicate borrowers' covenant calculations depending on accounting treatment, the timing of recognition, customer reimbursement obligations and credit agreement language, say attorneys at Mayer Brown.
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Power To The Paralegals: Burnout As A Structural Problem
Law firm leadership can best retain their paralegals not by encouraging self-care, but by seeking top-down structural solutions for the quiet proliferation of responsibilities and the vicarious exposure to client trauma that particularly drive burnout in this vital role, says Erika Sneeringer at Brockstedt Mandalas.
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Managing Post-IEEPA Tariff Refunds, Replacements And Risks
Companies and investors reeling from the rapid changes resulting from February's U.S. Supreme Court ruling that the International Emergency Economic Powers Act doesn't authorize tariffs should focus on understanding the duty refund process, the likely replacement tariffs and the operational ways they can minimize their tariff exposure, say attorneys at Debevoise.
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Wire Fraud Ruling May Upend White Collar Enforcement
A Texas federal court’s recent decision in U.S. v. Garza, dismissing wire fraud charges arising from an alleged $1 billion tax shelter scheme, advances a broader constitutional principle that could affect sentencing and reshape charging practices across white collar criminal cases involving specialized statutory regimes, say attorneys at Benesch.
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Economic Questions To Ask Amid Tariff Refund Class Actions
The U.S. Supreme Court's recent holding that the International Emergency Economic Powers Act doesn't authorize the president to impose tariffs has sparked class actions, but determining whether a retailer received a windfall is complex, even if it passed tariff costs into consumer prices before receiving a refund, say economists at Ankura Consulting Group.
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Cow Horse Makes Me A Better Lawyer
Moving an unwilling 800-pound cow while riding a horse at high speed is exhilarating, a little unhinged and, at least for me, a surprisingly effective training ground for litigation — both demand focus, preparation over rigid planning and the willingness to act despite fear, says Ashley Zitrin at Glenn Agre.
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Checking For AI Errors Is Now A Two-Way Street
A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.