News & Analysis as of May 22, 2025

Internal Revenue Service

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Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

Morgan Lewis on 2/6/2025

Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more

Tax Court in Brief | Thomas v. Comm’r | Interpretation of Section 6015(e)(7)(B): “Newly Discovered or Previously Unavailable...

Freeman Law on 2/20/2023

Summary: This is a case of first impression concerning the meaning of “newly discovered or previously unavailable evidence” as contemplated by I.R.C. § 6015(e)(7)(B): “Any review of a determination made under this section...more

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Internal Revenue Code (IRC) › Evidence › Internal Revenue Service

Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

Tax Court in Brief | Thomas v. Comm’r | Interpretation of Section 6015(e)(7)(B): “Newly Discovered or Previously Unavailable...

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