Federal
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October 16, 2025
IRS Mishandled Co.'s Payment Plan Request, Tax Court Says
The Internal Revenue Service improperly rejected a home health agency's request for an installment agreement to pay overdue taxes, the U.S. Tax Court said Thursday in ordering the agency's appeals office to reconsider the request.
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October 16, 2025
Tax Court Denies $2M Theft Deduction For Lack Of Evidence
A couple isn't allowed to claim a $2 million tax deduction for theft because they couldn't prove they were actually robbed or deceived, the U.S. Tax Court said Thursday.
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October 16, 2025
IRS Agents Lose Defamation Suit Against Hunter Biden's Atty
An attorney who defended Hunter Biden against criminal tax charges was only expressing his legal opinion when he accused Internal Revenue Service agents of illegally disclosing his client's private tax information, a D.C. federal judge ruled in dismissing the agents' complaint for defamation.
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October 16, 2025
Ga. Tax Worker Seeks Interest On Chrisley Slander Award
A Georgia Department of Revenue employee who was awarded $755,000 in her slander case against former reality star and convicted fraudster Todd Chrisley asked a federal judge to grant her post-judgment interest, which she said was mandatory but not spelled out in her judgment.
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October 16, 2025
Applicable Federal Rates To Slide For 4th Month
Applicable federal rates for income tax purposes will continue a monthslong slide in November, the Internal Revenue Service said Thursday, with dips for a fourth consecutive month after a July rebound.
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October 16, 2025
Justices Urged To Hear Mich. Tax Foreclosure Case
A property owner has asked the U.S. Supreme Court to weigh in on her case alleging a Michigan county improperly kept the excess proceeds of her tax-foreclosed home sale, arguing the justices should settle a conflict among circuits and calling the state's process to claim such proceeds too restrictive.
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October 16, 2025
Tax Prep Co. Loses Challenge To IRS E-File Ban
The IRS didn't violate a tax preparation company's constitutional rights or administrative law in barring it from filing returns electronically, a New York federal judge ruled, saying the agency was allowed to issue the suspension after investigating the company for filing fraudulent returns.
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October 16, 2025
Firm's Case Against GILTI Regs Can Proceed, DC Judge Says
An Israeli law firm's suit alleging that U.S. Department of the Treasury regulations regarding overseas income create disproportionate burdens for small entities may continue, a D.C. federal judge said, though dismissing a parallel claim brought by an individual attorney.
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October 15, 2025
Goldstein Can't Dismiss 2016 Tax Charges As Time-Barred
A Maryland federal judge denied SCOTUSblog co-founder Tom Goldstein's motion to dismiss four of the 22 federal tax charges brought against him in January, ruling that his defense that the counts stemming from the 2016 tax year should be time-barred will have to be raised at trial.
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October 15, 2025
11th Circ. Denies Veteran's Appeal Of Bias Suit Dismissal
The Eleventh Circuit on Wednesday affirmed a district court's ruling against a veteran who said he faced disability discrimination, retaliation and a hostile work environment at the IRS after the agency failed to accommodate his request to work from the office during the COVID-19 pandemic.
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October 15, 2025
Tax Court Says Easement Fraud Penalties Don't Require Jury
The U.S. Tax Court refused to throw out civil fraud penalties faced by a partnership accused of overvaluing a conservation easement tax deduction, rejecting the partnership's reliance on a U.S. Supreme Court ruling that limited federal agencies' authority to impose certain penalties without a jury trial.
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October 15, 2025
NJ Org Selling $189 Shoes Isn't Exempt, Tax Court Says
A New Jersey organization that claimed to help children cannot have tax-exempt status, the U.S. Tax Court said Wednesday, finding it mostly aimed to earn profits, including by selling $189 shoes designed by its founder.
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October 15, 2025
Sabre Says British Airways Must Reimburse For UK Digital Tax
Flight booking giant Sabre sued British Airways over a digital tax bill it says it was required to pay the U.K. on the airline's behalf, claiming the airline was contractually obligated to reimburse Sabre for the expense but has refused.
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October 15, 2025
Morgan Lewis Adds Ex-IRS Special Counsel As DC Partner
A former special counsel at the Internal Revenue Service's chief counsel's office has moved to Morgan Lewis & Bockius LLP's tax-exempt organizations team, where he'll continue working on issues related to charitable giving groups and other organizations.
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October 15, 2025
Tarter Krinsky Real Estate Chair Sees Office Market 'Normalcy'
Despite lingering economic questions, the office market is starting to reach a state of "normalcy," Tarter Krinsky's real estate leader told Law360 in a recent interview.
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October 15, 2025
NYC Hotel Must Hand Over Tax Credits In Bankruptcy
The owners of a boutique hotel in Brooklyn and its management company must return pandemic-era refundable tax credits that they received as the hotel filed for Chapter 11 bankruptcy protection, a New York bankruptcy judge ruled, saying they had unfairly pocketed the money at the bankruptcy estate's expense.
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October 14, 2025
GOP Bill Would Codify Trump Private Equity 401(k) Order
A Montana Republican lawmaker announced Tuesday the introduction of a bill that would codify President Donald Trump's executive order that aims to make it easier for retirement plans to invest in nontraditional 401(k) assets like private equity and cryptocurrency.
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October 14, 2025
Relief Concerns Grow As Sectoral Tariff Actions Build
Importers' hopes for relief from industrywide tariffs are lagging alongside the trade deals President Donald Trump is trying to broker for some goods, while the administration's accelerated rollout of sectoral levies is also stoking concerns the government may be hamstringing its onshoring goals.
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October 14, 2025
Buy.com Founder's $16M Tax Bill Untimely, 10th Circ. Told
The founder of now-defunct Buy.com is challenging a nearly $16 million tax bill before the Tenth Circuit, arguing that the Internal Revenue Service failed to obtain valid consent to extend the statute of limitations for assessing the levy.
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October 14, 2025
Six Pension Plans Settle In $2.1B Danish Tax Fraud Case
Six pension plans have settled claims by Denmark's tax agency accusing them of participating in a $2.1 billion scheme that fraudulently claimed refunds on tax withheld from stock dividends, with a New York federal court dismissing the allegations Tuesday.
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October 14, 2025
'Bitcoin Jesus' Paid $50M In Tax Deal, US Says
The U.S. asked a California federal court Tuesday to dismiss its criminal tax case against a cryptocurrency investor known as Bitcoin Jesus, disclosing that he has paid the $50 million he owed for hiding bitcoin from the IRS after renouncing his U.S. citizenship more than a decade ago.
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October 14, 2025
Floridian Must Pay $1.6M After Default Judgment In FBAR Suit
A tax preparer is on the hook for $1.6 million in penalties for foreign bank accounts that he tried to conceal, a Florida federal court found in a default judgment after he failed to respond to the U.S. government's suit.
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October 14, 2025
High Court Says Blackfeet Members Can't Join Tariff Dispute
The U.S. Supreme Court denied a bid by members of the Blackfeet Nation to join its review of suits challenging the legality of President Donald Trump's emergency tariffs, who had argued that their inclusion in the dispute is crucial to protect Indigenous rights under federal law.
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October 14, 2025
Miss. Partnership Challenges $89M Nixed Easement Deduction
A Mississippi partnership is entitled to an $89 million tax deduction for donating a conservation easement that protected land that could have been used for mining, despite the IRS' claim that the partnership failed to prove the gift's value, the partnership told the U.S. Tax Court.
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October 10, 2025
The Tax Angle: IRS Leadership Changes Amid Gov't Shutdown
The federal government shutdown doesn't appear any closer to being resolved on Capitol Hill, but that hasn't stopped the U.S. Treasury Department from pushing ahead with a dizzying amount of changes in the Internal Revenue Service's top leadership. Here's a rundown of changes at the IRS in the past week.
Expert Analysis
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How Energy Cos. Can Prepare For Potential Tax Credit Cuts
The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.
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DOJ Has Deep Toolbox For Corporate Immigration Violations
With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.
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Del. Dispatch: General Partner Discretion In Valuing Incentives
In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.
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Move Beyond Surface-Level Edits To Master Legal Writing
Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.
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9th Circ. Has Muddied Waters Of Article III Pleading Standard
District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.
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Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny
After decades of a quiet governmental acceptance of tax-exempt status, universities are facing unprecedented and public pressure to defend themselves, and must consider how to protect this valuable status, say attorneys at Eversheds Sutherland.
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Tax Court Ruling Sets High Bar For Limited Partner Exception
The U.S. Tax Court’s recent decision in Soroban Capital Partners v. Commissioner endorsed the IRS’ use of functional analysis to determine whether the limited partner exception applied for taxation under the Self-Employed Contributions Act, highlighting the intense factual analysis that will occur during audits, says Erin Hines at Akerman.
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How AI May Reshape The Future Of Adjudication
As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.
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When Legal Advocacy Crosses The Line Into Incivility
As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.
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Attacks On Judicial Independence Tend To Manifest In 3 Ways
Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.
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Increased Tariffs Create Opportunity To Protect IP Rights
Heightened tariffs on certain foreign imports have created operational and fiscal challenges for companies, but the corresponding increase in customs inspections could offer a silver lining of more consistent enforcement against counterfeit and infringing goods, says Andraya Pulaski Brunau at Day Pitney.
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Dissecting House And Senate's Differing No-Tax-On-Tips Bills
Employers should understand how the House and Senate versions of no-tax-on-tips bills differ — including in the scope of related deductions and reporting requirements — to meet any new compliance obligations and communicate with their employees, say attorneys at Greenberg Traurig.