Social Media Ideas for Tax-Related Court Cases

Taxation of Cryptocurrency Staking Rewards under Section 61

Alvie N. Paschall and Patricia C. Paschall v. Commissioner of Internal Revenue, T.C. Memo. 2026-46 (June 4, 2026) The litigation in Paschall v. Commissioner involves the tax t...

Summary Judgment Granted in Case Involving Fraudulent Failure to File and Improper Corporate Deductions

Shryrock v. Commissioner, T.C. Memo. 2026-44, May 28, 2026 In the recent decision of Shryrock v. Commissioner, T.C. Memo. 2026-44, the United States Tax Court addressed a sign...

Treasury Regulation Section 1.951A-2(c)(5) Held Invalid: Court of Federal Claims Rules Against Amortization Denials in P...

Keysight Technologies, Inc. & Subsidiaries v. United States, No. 25-137 (Fed. Cl. July 2, 2026) The United States Court of Federal Claims has held that the Department of...

The Soroban Capital Partners SECA Tax Controversy: Partnership Items, Functional Analysis, and Appellate Oral Arguments

Soroban Capital Partners LP v. Commissioner, 161 T.C. 310 (2023); Soroban Capital Partners LP v. Commissioner, T.C. Memo. 2025-52; Soroban Capital Partners LP v. Commissioner,...

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

Substantiating Mortgage Interest: The Risks of Unverifiable Claims and Statutory Misinterpretations

Igboke v. Commissioner, Bench Opinion, Docket No. 12275-24 (U.S. Tax Ct. June 3, 2026) In the recent decision of Igboke v. Commissioner, the U.S. Tax Court addressed a funda...

Tax Fraud Blotter: Any port in a storm

Using his personhood; SNAP redemptions; Ponzi-like payments; and other highlights of recent tax cases.

Tax Fraud Blotter: Not so great

IRS impersonation; Lootland; conduit scheme; and other highlights of recent tax cases.

Tax Fraud Blotter: At death's door

Lulling tactics; up to 152 years in prison; big-ticket items; and other highlights of recent tax cases.

Pleading Requirements for the Employee Retention Credit: Analyzing the Dismissal of Tapestry Senior Housing

Tapestry Senior Housing Management, LLC v. United States, Case No. 25-cv-3419 (LMP/EMB), 2026 WL 18388 (D. Minn. June 25, 2026). The Employee Retention Credit (ERC) under Inte...

Capital Contributions vs. Compensation: Analyzing Ownership and Taxability in Manufacturing Expansion Agreements

Thermal Circuits, Inc. v. Commissioner, T.C. Memo. 2026-29 (July 7, 2026) In the complex intersection of supply chain financing and tax characterization, the distinction betwe...

Medicaid Gross Receipts, Cohan Estimations, and the Limits of Professional Reliance: A Technical Analysis of Branch v. C...

Branch v. Commissioner, T.C. Memo. 2026-51, Docket No. 7214-20 (Filed June 17, 2026) In Branch v. Commissioner, T.C. Memo. 2026-51, the United States Tax Court addressed sev...

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...

Analyzing Procedural Timeliness in Tax Litigation: The Karps’ Automatic Extension Ruling

Selwyn Karp and Barbara Adams-Karp v. The United States, Case No. 1:23-cv-00926-MRS, filed May 21, 2026 The U.S. Court of Federal Claims issued a significant opinion in Selwyn Karp...

Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case

David Schultz & Michael Rapoport (Bloomberg Law): Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case A panel of federal appellate judges were receptive to Coca-Cola Co....

Bad-Facts FLP Causes Estate Tax Inclusion Under IRC Section 2036

An accuracy-related penalty was imposed on the tax deficiency.

Section 115BBE Controversy Nearing Closure: Rajasthan High Court Joins the Taxpayer Camp

Section 115BBE Controversy Nearing Closure: Rajasthan High Court Joins the Taxpayer Camp   Enhanced 60% Tax Rate Cannot Be Applied Retrospectively, Says Rajasthan High Court Few pr...

Tax Fraud Blotter: Drinking and draining

Flat-out invented; 500 months; diverted income; and other highlights of recent tax cases.

Tri-State, First Source and the ERC refund clock

Recent court cases and IRS actions are changing the litigation playbook for taxpayers appealing Employee Retention Credit claims that have been denied.

Strict Enforcement of Tax Refund Statutes of Limitations: Court of Federal Claims Dismisses Untimely Claim in Suvarna v....

Suvarna v. United States, No. 25-902T (Fed. Cl. July 1, 2026) The United States Court of Federal Claims has dismissed a taxpayer's suit for lack of subject-matter jurisdiction...

Tax Court Bench Opinion in Sleiman: Nominal S Corporation Ownership and the Judicial Expansion of the Domestic Abuse Exc...

Sleiman v. Commissioner, No. 19155-24 (T.C. May 6, 2026) (oral findings of fact and opinion rendered pursuant to T.C. Rule 152) For tax professionals representing clients in j...

Equitable Relief for Erroneous Tax Refunds: An Analysis of the Fourth Circuit's Reversal in LaRosa v. Commissioner

Catherine L. LaRosa v. Commissioner of Internal Revenue, CA 4, Case No. 24-2034 (May 18, 2026) vacating and remanding 163 T.C. No. 2 (July 17, 2024) The availability of equi...

The Impermeable Reach of Section 6672: Joint and Several Trust Fund Liability and the Demise of the Delegation Defense

United States v. Estate of Richard T. Cole, Jr., et al., United States District Court for the Eastern District of Michigan, (Case No. 22-cv-12916, May 15, 2026) For tax prof...

Settlement Agreements, Forms 1099, and Tax Trouble: Lessons from Adusei v. Auer

A recent federal decision out of Arizona offers a useful reminder about the tax treatment of settlement payments, as well as risks that arise when settlement agreements fail to add...