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Tax Controversy Report

Petitions

Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional

By Adam Young on August 5, 2026

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
Posted in Civil Tax, Commissioner of Internal Revenue, Federal Taxes, General Tax Controversy News & Updates, IRS Audits, IRS Chief Counsel, IRS Large Business and International (LB&I) Division, Legislation, Small Business/Self-Employed, Tax Controversy Litigation

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

By Brian Bernhardt, Matthew D. Lee, Kristy Caron, Jonathan Wasser & Meeren Amin on April 17, 2026

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
Posted in Civil Tax, Commissioner of Internal Revenue, Federal Taxes, General Tax Controversy News & Updates, Internal Revenue Code, Internal Revenue Service (IRS), IRS Chief Counsel, IRS Taxpayer Advocate Service (TAS), Legislation, Refunds, Tax Controversy Litigation, Tax Reform, Taxpayer Advocate, U.S. Tax Court

Tax Controversy Report

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