Tax Controversy Litigation

New Trial Cities, Broader Access, and a Pilot of a Smarter Calendar

On September 8, 2026, Chief Judge Urda announced three significant changes to how the United States Tax Court…

Continue Reading Your U.S. Tax Court Case Just Got Closer to Home

If you own a business or reside in Lancaster County, pay close attention: the IRS confirmed in a July 21, 2026 letter that 20 revenue officers will be conducting face-to-face…

Continue Reading IRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to Know

In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to…

Continue Reading Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional

Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a…

Continue Reading Back to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the Delorean

Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS.  The passive activity loss rules under I.R.C.

Continue Reading No Points for Participation: Passive Activity Rules and Loss Limitations

This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…

Continue Reading The Taxpayer Assistance and Service Act: Title III: Judicial Review

On February 26, 2026, Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) introduced the Taxpayer Assistance and Service Act, a bipartisan legislative package proposing…

Continue Reading Senators Introduce Bipartisan Legislation to Significantly Improve Federal Tax Administration and Procedure

Fox Rothschild attorneys Matthew D. Lee, Brian C. Bernhardt, and Jonathan M. Wasser have authored a client alert regarding a new refund opportunity for taxpayers who accrued IRS…

Continue Reading Court Ruling Creates Refund Opportunity for Pandemic-Era IRS Interest and Penalties