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....

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...

Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy Barrier

Zhang v. Internal Revenue Service, No. 26-cv-00525-VKD (N.D. Cal. July 30, 2026) The compliance burden for U.S. taxpayers receiving foreign gifts has intensified over the la...

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...

The Invalidity of the Extraordinary Disposition Rules: Tax Court Upholds the Plain Meaning of Section 245A in Siemens v....

Siemens Medical Solutions USA, Inc. & Consolidated Subsidiaries v. Commissioner, 167 T.C. No. 5 (2026) In Siemens Medical Solutions USA, Inc. and Consolidated Subsidiaries...

Latest Tax Updates: Section 7508A Refund Claims, Whistleblower Award Eligibility, and Court Restrictions on IRS Collecti...

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...

The Tax Court Open Door: Why the BBA Partnership Petition Deadline Is Not Jurisdictional

Big Apple Tompkins Realty LLC, Mojahed H. Bhutta, Partnership Representative v. Commissioner of Internal Revenue, 167 T.C. No. 7 (August 5, 2026) In tax controversy, the lin...

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...

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...

Tax Court Bars Above-the-Line Deduction for Fair Credit Reporting Act Legal Fees: Analyzing Eiler v. Commissioner

James Wendelin Eiler and Kathryn Ann Eiler, Deceased v. Commissioner of Internal Revenue, 167 T.C. No. 3, July 14, 2026 For tax practitioners managing the tax consequences of...

Tax Fraud Blotter: Win some, lose some

Back-to-school haircuts; two revenue books; voluntary surrender; and other highlights of recent tax cases.

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.

Technical Analysis of Piton Holdings, LLC v. Commissioner: Syndicated Conservation Easements, Mid-Day Partnership Variat...

Piton Holdings, LLC, David L. Hall, Partnership Representative v. Commissioner of Internal Revenue, 167 T.C. No. 4 (filed July 15, 2026) In Piton Holdings, LLC v. Commissioner...

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...

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...

Tax Fraud Blotter: No hope with DOPE!

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

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

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...