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Administrative Procedure Act Tax Litigation

McDermott Will & Emery

Sixth Circuit Denies Proceeds Regulation Rehearing Request, Sets Up a Circuit Split

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The US Court of Appeals for the Sixth Circuit recently denied a taxpayer’s request for a rehearing en banc in Oakbrook Land Holdings, LLC v. Commissioner, No. 20-2117, leaving a highly contested conservation easement...more

McDermott Will & Emery

Sixth Circuit Sides with Taxpayer in APA Challenge to Reportable Transaction Regime

We previously posted about the US Supreme Court’s opinion in CIC Servs., LLC v. IRS, which allowed a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. In that post, we noted...more

McDermott Will & Emery

IRS Chief Counsel Signals Increased Tax Enforcement

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The Internal Revenue Service (IRS) Chief Counsel is the chief legal advisor to the Commissioner of Internal Revenue on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Laws....more

Freeman Law

Freeman Law’s Top 10 Tax Court Cases of 2020

Freeman Law on

The 2020 year was . . . well, interesting. So, too, were the Tax Court decisions for the year. In this Insight, Freeman Law takes a closer look at the top 10 Tax Court cases of 2020. As a reminder, Freeman Law...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

McDermott Will & Emery

An Uneven Playing Field: Judicial Deference to State Tax Administrator Interpretations

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Judicial deference to state tax agencies puts taxpayers at a steep disadvantage and wastes time and resources on costly tax disputes. A united advocacy effort can help promote passage of state-level legislation that takes the...more

Morrison & Foerster LLP

No (Tax) Man Is Above the Law: The Tax Court Rejects Final Cost-Sharing Regulations in Altera Corporation and Subsidiaries v....

Our 26th President Theodore Roosevelt famously contributed to the American canon the following: “No man is above the law and no man is below it; nor do we ask any man’s permission when we ask him to obey it.” The notion that...more

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