IRS Can Bring Valuation Case to Trial Despite IRC Section 7517 Noncompliance
Court refuses to grant summary judgment based on failure to provide notice under IRC Section 7517.
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Court refuses to grant summary judgment based on failure to provide notice under IRC Section 7517.
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A recent federal court decision, Huang v. United States, offers important guidance for U.S. persons who have received large gifts from foreign persons, and failed to timely file Fo...
IRS impersonation; Lootland; conduit scheme; and other highlights of recent tax cases.
The Court of Appeal has confirmed in HMRC v M R Currell Ltd that, prior to the introduction of the disguised remuneration rules, a genuine and repayable loan made via an employee b...
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2026 – April 9, 2026. April 3, 2026: The White House proposed sig...
Failed election campaign; six-figure salary; online scam; and other highlights of recent tax cases.
Associate Alabama Tax Tribunal Judge Ralph M. Clements, III, recently appointed by Gov. Kay Ivey, has hit the ground running and issued two well-reasoned rulings that nevertheless...
Flat-out invented; 500 months; diverted income; and other highlights of recent tax cases.
On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was “relevant” and applied to deny Liberty Global, Inc. a $...
Not a ghost of a chance; all's Wells; fictitious spouses; and other highlights of recent tax cases.
FCC strikes down Section 7E of Income Tax Ordinance
Ghost payroll; non-existent businesses; save you from paying; and other highlights of recent tax cases.
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...
CryptoPunks; Eight Percent Fund; fake Transaction Summaries; and other highlights of recent tax cases.
Cases where returned income exceeds ₹15 lakh must be handled by the ACIT or higher authorities Not doing so would render Assessment void ab-initio Reassessment under Section 147...
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 23, 2026 – March 31, 2026. March 23, 2026: A US Treasury Inspector G...
How Innocent Tax Mistakes Turn into Costly Litigation There was a time when income tax litigation usually began with raids, surveys, dramatic searches, and sudden visits by tax o...
Income Tax Reopening Based on External Input Set Aside; SC Refuses Interference In this case, the High Court addressed the validity of reopening tax assessments based on external “...
The Court of Appeal has confirmed in Burlington Loan Management DAC v HMRC that “obtaining the benefit of” a tax treaty is not the same as “taking advantage of” it. The treaty anti...
The Supreme Court refused to interfere with a tax department appeal against Britannia Industries Ltd, upholding a Calcutta High Court ruling that had set aside an Income Tax revisi...
A judge ruled the IRS can't classify micro-captive insurance as a listed transaction, but allowed classifying it as a "transaction of interest."
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 20, 2026 – May 1, 2026. April 23, 2026: The IRS has reportedly begun...
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