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
Tax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional
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 JurisdictionalHorse Breeding and Training Expense Deductions? Tax Court Says Neigh
In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance
Continue Reading Horse Breeding and Training Expense Deductions? Tax Court Says NeighThe Taxpayer Assistance and Service Act: Title III: Judicial Review
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 ReviewPartnership Interest Sale Inventory Gain is Not U.S. Source Income
On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner
Continue Reading Partnership Interest Sale Inventory Gain is Not U.S. Source IncomeTax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties.
Continue Reading Tax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
Tax Court Holds IRS Complied with Supervisor Approval Requirement
The Tax Court’s recent opinion in Roth v. Commissioner, T.C. Memo. 2017-248, raises interesting issues about the need for supervisor approval when the IRS asserts penalties. In 2007, the
Continue Reading Tax Court Holds IRS Complied with Supervisor Approval Requirement
Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
The issue before the Tax Court in Huzella v. Commissioner, T.C. Memo. 2017-210, centered around a coin business on eBay, and whether the petitioner, Thomas Huzella, could substantiate his
Continue Reading Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
Tax Court Denies Treaty Benefit to Canadian Post–Doctoral Fellow
In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation
Continue Reading Tax Court Denies Treaty Benefit to Canadian Post–Doctoral Fellow
Tax Court Broadens Foreign Earned Income Exclusion
The Tax Court’s recent decision in Linde v. Commissioner, T.C. Memo. 2017-180, brought good news to taxpayers working outside the United States. In Linde, the Tax Court held
Continue Reading Tax Court Broadens Foreign Earned Income Exclusion