Social Media Ideas for Tax-Related Court Cases

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....

Gross Income Realization vs. Nontaxable Receipts: Tax Court Evaluates Unrestricted Art Deal Funds in Tunkl v. Commission...

Tunkl v. Commissioner, T.C. Memo. 2026-83 (Sept. 10, 2026) For federal income tax professionals advising high-net-worth clients, dealers, and corporate entities engaged in inf...

U.S. Tax Court Upholds Excise Tax Liability for Excess Benefit Transaction

The Burden of Proof in Certified Mailing: Analyzing Wales v. Commissioner and Jurisdictional Thresholds

Wales v. Commissioner, T.C. Memo. 2026-82, (Sept. 3, 2026) In the practice of tax controversy, few issues are as critical as the precise boundaries of the United States Tax Co...

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...

Tax Administration, Sham Partnerships, and Voluntary Compliance: Understanding the Eleventh Circuit’s Affirmation of the...

Filipowski v. Commissioner, No. 25-11382 (11th Cir. 2025), September 2, 2026 For tax professionals representing clients with significant tax delinquencies, the Offer-in-Comp...

Deficiencies, Defective USPS Form 3877, and the Limits of Tax Court Jurisdiction: Analysis of Lindsey v. Commissioner

Lindsey v. Commissioner, T.C. Memo. 2026-94 (Sept. 24, 2026) In federal tax controversy practice, few procedural hurdles carry as much consequence as the mailing of a Statutor...

Tax Fraud Blotter: Fairway to heaven

Fibbing for a 68-foot yacht; four bedroom in Beverly Hills; and other highlights of recent tax cases.

Foreign Tax Credits Against the Net Investment Income Tax: A Critical Analysis of the Federal Circuit’s Decisive Rulings...

Estate of Paul Bruyea v. United States, F.4th , No. 25-1563, ECF No. 58 (Fed. Cir. Aug. 31, 2026), reversing Bruyea v. United States, 174 Fed. Cl. 238 (2024). Matthew Christ...

Form 16 delay led to ITR non-filing and ₹3.74 lakh penalty: How a salaried employee won his case

A salaried employee’s failure to file his ITR after switching jobs led to a ₹3.74 lakh penalty, even though the TDS deducted by his employers was reflected in Form 26AS. ITAT Delhi...

Equitable Tolling and Statutory Notice Validity Under the BBA Audit Regime: An Analysis of Kings Road Property, LLC v. C...

Kings Road Property, LLC v. Commissioner, 167 T.C. No. 11 (2026) In Kings Road Property, LLC v. Commissioner, 167 T.C. No. 11 (2026), the United States Tax Court addressed two...

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...

Tax Fraud Blotter: Keep on truckin'

Special Tax Shelter Strategy; ghost prepared; material falsehoods; and other highlights of recent tax cases.

Tax Fraud Blotter: Keys to the kingdom

Check churning; a Maserati and a McLaren; private family foundation; and other highlights of recent tax cases.

The High Bar for Equitable Tolling in Tax Practice: Lessons from the Eighth Circuit’s Final Ruling in Boechler, P.C.

Boechler, P.C. v. Commissioner of Internal Revenue, No. 25-2620, (8th Cir. Aug. 10, 2026) For tax professionals, the landmark Supreme Court decision in Boechler, P.C. v. Com...

The Supreme Court’s 2025 Term in Tax

Jasper L. Cummings, Jr. (Alston & Bird), The Supreme Court’s 2025 Term in Tax, 192 Tax Notes Fed. 867 (Aug. 3, 2026): This is my 15th annual review of Supreme Court opinions re...

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...

Functional Reality vs. Form Under SECA: The Second Circuit’s Affirmance in Soroban Capital Partners and the Evolving Cir...

Soroban Capital Partners LP v. Commissioner of Internal Revenue, Nos. 25-2079 (L), 25-2250 (CON) (2d Cir. Sept. 17, 2026), aff’g 161 T.C. 310 (2023), and T.C.M. (RIA) 2025-52....

She declared Rs 43,796, misses Rs 14.02L; hit with 200% penalty, but ITAT gave relief

This is the case of a 57-year old non-resident Indian (NRI) woman who ended up under-reporting her income when she filed her Income Tax Return, and the gap was huge.

Trust Fund Recovery Penalty Willfulness and the Capping Effect of Corporate Offers-in-Compromise: A Technical Analysis o...

Amodio v. Commissioner, T.C. Memo. 2026-96, Docket No. 9959-22L (Sept. 28, 2026) For tax controversy practitioners, Certified Public Accountants, and Enrolled Agents, naviga...

Getting into Tax Court

Here in Hawaii, it’s a big deal for the state to have a stable source of revenue.  Tax lawsuits have the potential to tie that revenue up, so here, as well as in many other states,...

Tax Fraud Blotter: No hope with DOPE!

Improper personal expenses; satisfied clients; unpaid principal; and other highlights of recent tax cases.

Tax Fraud Blotter: Jet skis, dirt bikes and trailers, oh my!  

"Godfather" sculptures; designer handbags; nonprofit embezzlement; and other highlights of recent tax cases.

The Intersection of Vested Development Rights and Valuation in Conservation Easements: Analyzing Malibu Valley Land, LLC...

Malibu Valley Land, LLC v. Commissioner, T.C. Memo. 2026-68 (Aug. 17, 2026) The valuation of noncash charitable contributions has long been a battleground between taxpayers an...