Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law
Videocast: SALT Scoreboard – 2019 year in review
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Effective Strategies for Elevating Issues
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Overview of IRS Appeals Judicial Approach & Culture Project (AJAC)
Jones Day Presents: Strategies for Dealing with the IRS: Alternative Dispute Resolution
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
A recent Ninth Circuit decision, Roman v. Commissioner (Mar. 18, 2026), reinforces how narrow the tax-free treatment of settlement proceeds is. In most cases, settlement payments are taxable unless they clearly compensate for...more
Associate Alabama Tax Tribunal Judge Ralph M. Clements, III, recently appointed by Gov. Kay Ivey, has hit the ground running and issued two well-reasoned rulings that nevertheless illustrate traps for unwary taxpayers and...more
A US Treasury Inspector General for Tax Administration (TIGTA) report found that the IRS’s approach to auditing large partnerships has been ineffective due to resource constraints and inefficient selection processes,...more
Kilpatrick’s David Hughes, Jordan Goodman, and Samantha Breslow recently presented on the topic of “State Tax Cases, Issues & Policy Matters to Watch” at the COST Mid-West Regional State Tax Seminar in Omaha. ...more
Washington, long one of the few states without a personal income tax, has enacted a 9.9% tax on income above $1 million. The law is set to take effect in 2028 and is expected to face prompt constitutional challenges....more
We previously discussed the US District Court for the District of Arizona’s April 2025 order denying a motion for a preliminary injunction filed by two tax preparation firms challenging the Internal Revenue Services’ (IRS)...more
A recent U.S. Tax Court decision (Jeffrey Pesarik v. Commissioner of Internal Revenue) highlights the importance of properly substantiating property tax basis and qualifying for the exclusion of capital gains on the sale of a...more
Key Takeaways - On March 23, 2026, the U.S. Tax Court entered a stipulated decision in Agate Holdings LLC, Agate Manager LLC v. Commissioner under which the IRS conceded the partnership’s full $48.3 million deduction for a...more
The US Tax Court is considering developing a disciplinary framework for the misuse of artificial intelligence (AI) in litigation following concerns raised by Judge Mark V. Holmes regarding lawyers citing AI-generated,...more
When things start to go badly in a business, its owners may feel compelled to take certain extraordinary, and usually ill-conceived, measures “to keep the doors open and the lights on.” For instance, when faced with a...more
In Ankner v. United States, a federal jury rejected the Internal Revenue Service’s attempt to impose approximately $4 million in promoter penalties under IRC § 6700 against a captive insurance manager....more
Why only seek an alternative formula when you can win under the normal formula? A corporate taxpayer won under a special-industry normal apportionment formula, and it won the right to use an alternative apportionment formula...more
Although many of the procedural rules for auditing partnerships at the federal level have changed under the Bipartisan Budget Act of 2015 (the “BBA”), some principles—like the effect of actual notice—remain the same. Under...more
In a recently issued decision, a Texas intermediate appellate court affirmed the decision of the trial court granting summary judgment to a manufacturer in its sales tax refund appeal, finding that the property and services...more
Many of us are familiar with how a limited liability company can be a disregarded entity for income tax purposes. There is a similar concept for trusts, so-called “grantor trusts” for income tax purposes, which means that the...more
Welcome to the latest edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. We pull together the items we deem most important to provide...more
The Tax Court has previously held that a partner who contributes his own note to a partnership in exchange for a partnership interest takes no basis in the interest and their capital account is not credited for the value of...more
The Employee Retention Credit may be closed to new filings, but the controversy surrounding unpaid and disallowed claims is very much alive. For many businesses, the real risk in 2026 is no longer just whether the IRS will...more
In February 2026, the Internal Revenue Service (IRS) announced that, as of December 31, 2025, it had closed all non-examined Employee Retention Credit (ERC) claims....more
The Internal Revenue Service (IRS) recently filed its first written response to arguments used widely by cannabis taxpayers as justification for not paying Section 280E taxes. The closely-watched U.S. Tax Court case, New...more
Kilpatrick’s Jordan Goodman recently presented on the topic of “Sales Tax Case Law – Lessons from the Court” at the Advanced Sales and Tax Workshop in Dallas. ...more
Upsetting a string of wins for the Internal Revenue Service ("IRS") in the Tax Court, the Fifth Circuit recently rejected the "functional analysis" test for determining whether a limited partner's partnership income is...more
In an eventful start to 2026, the Federal Court of Appeal (FCA) has already released five notable tax decisions. Signalling an active and consequential year ahead, here’s what you need to know about these decisions...more
A recent Fifth Circuit decision, Sirius Solutions LLLP v. Commissioner, brought welcome news for the investment funds industry. In Sirius, the Fifth Circuit held that the Self-Employment Contributions Act (“SECA”) “limited...more
Following a recent Court of Federal Claims decision, taxpayers may be able to seek tax refunds or abatement of interest and penalties assessed during the COVID-19 pandemic. Taxpayers who accrued interest or penalties between...more