U.S. Tax Court

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

In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the

Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

As part of its continuing guidance to taxpayers and practitioners about how its resumption of activities following the government shutdown is impacting pending matters, the Internal Revenue Service has published
Continue Reading IRS Publishes Frequently Asked Questions About Resumption of Tax Court Cases Following Shutdown