Social Media Ideas for Robert Willens

Unpacking the Substantiation and Alter-Ego Hurdles in Hank Risan v. Commissioner: A Technical CPA Analysis

Hank Risan, et al. v. Commissioner of Internal Revenue, T.C. Memo. 2026-78 (Sept. 2, 2026) Hank Risan is a California-based music enthusiast and inventor who claimed to have...

Law Professor Appeals Remote Taxation Case to New York High Court

Cameron Browne (Tax Analysts): Law Professor Appeals Remote Taxation Case to New York High Court Zelinsky, a professor at the Benjamin N. Cardozo School of Law in New York City, fi...

Commingled Funds, Unsubstantiated Deductions, and the Binding Form of Transactions: A Technical Tax Analysis of Reed v....

Scott L. Reed and Stacy N. Reed v. Commissioner of Internal Revenue, T.C. Memo. 2026-64, Docket No. 13757-20 (August 5, 2026) The United States Tax Court’s recent decision in...

Unmasking the $70 Million Dubai Fraud: A Technical Analysis of Section 165 Theft Loss Deductions in Deutsch v. Commissio...

Deutsch v. Commissioner, T.C. Memo. 2026-66, August 12, 2026 For tax professionals representing clients who have fallen victim to fraudulent investment schemes, securing a the...

New Jersey Tax Court Finds Holes in the Donuts and the Director’s Arguments

Tax Law Update: September 2026

The most notable tax law developments of the past month

Tax Law Update: July/August 2026

The most notable tax law developments of the past month

Double Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. Commissioner

Walter D. Prezioso & Kimberly J. Prezioso v. Commissioner, T.C. Memo. 2026-63, July 28, 2026 The taxpayer, Walter D. Prezioso, joined GSP Precision, Inc. (GSP)—an aerosp...

Predecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. Commissi...

HBM Holdings Co. v. Commissioner, 167 T.C. No. 6 (July 27, 2026) The United States Tax Court recently issued a reported decision in HBM Holdings Co. v. Commissioner, 167 T.C....

Wealth Tax Watch- A Mid-Year Update

There May Be a Billion-Dollar Tax Play Hidden in the LA Lakers Sale, and It Probably Won’t Happen

The Los Angeles Lakers are changing hands again. Less than a year after Guggenheim Partners CEO Mark Walter acquired control of the team in a transaction valuing the Lakers at $10...

Did You Receive Your Pied-à-Terre Tax Notice?

The Full Payment Requirement and the Presumption of Correctness: Jurisdictional Lessons from Pellegrino v. United States

Pellegrino v. United States, No. 1:26-cv-00403, 2026 WL (Fed. Cl. Aug. 20, 2026) In Pellegrino v. United States, No. 1:26-cv-00403 (Fed. Cl. Aug. 20, 2026), Judge Philip S....

The Wrapper Illusion

Can an LLC or partnership make tax anti-abuse rules disappear?

FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Insights for Tax Professionals from United States v...

United States v. Rund, No. 24-1958, ___ F.4th ___ (4th Cir. Sep. 4, 2026), affirming 743 F. Supp. 3d 779 (E.D. Va. 2024) As tax professionals representing clients with interna...

LerroSarbey Announces Acquisition of Levenson Katzin & Ballotta

When the Structure Isn’t Right: LLCs, Check-the-Box, and the §1045 Rollover (Part IV of IV)

Update in the Limited Partner Litigation

As I’ve previously written, in January, the Fifth Circuit ruled in Sirius Solutions, LLLP v. Commissioner that the term “limited partner,” as defined in section 1402(a)(13) (the so...

Rehearing Reversal: The Fifth Circuit’s Substitutive Management Test for the Limited Partner Self-Employment Tax Excepti...

K Alain, L.L.L.P. v. Commissioner of Internal Revenue, No. 24-60240, --- F.4th --- (5th Cir. Aug. 12, 2026), withdrawing and substituting for Sirius Solutions, L.L.L.P. v. Comm...

More on Tax-Aware Long-Short Investing Strategies

Loukia Gyftopoulou, Paige Smith & Charlie Wells (Bloomberg): The Ultrawealthy Tax Maneuver That’s Spooking Schwab and Fidelity For months, the brokerage had piled into one of t...

Treasury Raises Concerns About Tax-Aware Investment Products

At a Wall Street Tax Association seminar on July 21, 2026, Treasury officials discussed various strategies involving regulated investment companies in which Treasury has taken an i...

Bloomberg: Highland Capital Says IRS Wrongly Taxed Great Recession Hedge

David Schultz (Bloomberg), Highland Capital Says IRS Wrongly Taxed Great Recession Hedge: A troubled securities trading firm says the IRS is improperly taxing a more than $166 mill...

The Partnership That Never Was

A disconnect between administrative convenience and substantive tax law may lead to compliance errors.

DOJ Charges Former Linqto Head For Alleged Pre-IPO Fraud

William Sarris allegedly charged customers markups exceeding 200% on pre-IPO investments while misrepresenting prices and inventory to boost company revenue.