The Tax Court unanimously held that § 7701(o) requires a threshold relevancy determination before applying the two-prong economic substance test. In Patel v. Commissioner, the United States Tax Court ...
The Tax Court’s opinion provides U.S. businesses with greater certainty around tax treatment of major spending decisions, which will allow for better strategic planning of the kind of investments that ...
On December 1, 2025, the House of Representatives passed H.R. 5349, the “Tax Court Improvement Act,” with bipartisan support. The bill seeks ...
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Tax court consolidates Clinton Foundation whistleblower cases, signaling progress towards trial
A judge has agreed to consolidate two cases brought by whistleblowers against the IRS, alleging the tax agency failed to provide them with an award for information on the Clinton Foundation, according ...
Atlanta, Georgia, Jones Day, multinational law firm office building. (Photo by: Jeffrey Greenberg/Universal Images Group via Getty Images) Paul- Adams Quarry Trust LLC marks the third opinion in which ...
The U.S. Tax Court has been brutal in its treatment of so-called microcaptive insurance companies. These are captive insurance companies which have both made the Internal Revenue Code § 831(b) ...
Christmas 2025 federal holiday: This holiday season will look a little different for federal workers after US president Donald Trump signed an executive order expanding the Christmas break for 2025.
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