Social Media Ideas for Tax-Related Court Cases

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

Tax Fraud Blotter: Open to interpretation

Fugitive from justice; private school tuition; without clients' knowledge; and other highlights of recent tax cases.

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...

Tax Fraud Blotter: Fairway to heaven

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

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...

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...

Reconstructing Income, Substantiating Deductions, and Navigating Penalty Supervisory Approvals: Technical Lessons from R...

MD M. Rahman & Syeda Momotaz v. Commissioner, Docket No. 8286-23 (T.C. Oct. 7, 2026) (Bench Op. by Nega, J.) In MD M. Rahman & Syeda Momotaz v. Commissioner, Docket No...

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...

Tax Fraud Blotter: Friends in high places

Bold and arrogant; secure repeat business; questionable tax returns; and other highlights of recent tax cases.

Tax Fraud Blotter: Keep on truckin'

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

Substantiation, Partner Basis, and Methodologies: An Analysis of West v. Commissioner

West v. Commissioner, T.C. Memo. 2026-105, Oct. 7, 2026 The petitioner, Andrew B. West, was an entrepreneur involved in various commercial activities during the 2015 and 2016...

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: Jet skis, dirt bikes and trailers, oh my!  

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

Tax Fraud Blotter: Making waves in Hawaii

Millions on OnlyFans; 'Administrative Expenses;' cookie decorating class; and other highlights of recent tax cases.

Professional Sophistication and the Civil Fraud Penalty: How an IRS Auditor’s Own Expertise Sealed His Fate in Tax Court

Peter J. Janangelo, Jr. and Mary Ann Janangelo v. Commissioner of Internal Revenue, T.C. Summary Opinion 2026-8 (Tax Ct. Aug. 27, 2026) Tax professionals are often held to a h...

Tax Court Upholds Steep Penalties on Charity Insiders Who Diverted Funds

Rs 10L investment, different explanations: why ITAT deleted tax addition & penalty

The dispute arose after the income tax department received information about an investment of Rs 11.25 lakh made by a man with a wealth management firm. The assessing officer accep...