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Supreme Court of the United States Tax Court

The United States Supreme Court is the highest court of the United States and is charged with interpreting federal law, including the United States Constitution. The Court's docket is largely discretionary... more +
The United States Supreme Court is the highest court of the United States and is charged with interpreting federal law, including the United States Constitution. The Court's docket is largely discretionary with only a limited number of cases granted review each term.  The Court is comprised of one chief justice and eight associate justices, who are nominated by the President and confirmed by the Senate to hold lifetime positions. less -
Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

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Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

Downs Rachlin Martin PLLC

What Connelly v. United States Means for Closely-Held Businesses

The US Supreme Court recently issued a significant decision, impacting many closely-held businesses with buy-sell agreements funded by life insurance policies, Connelly v. United States, 144 S. Ct. 1406 (2024). In a 9-0...more

Pillsbury Winthrop Shaw Pittman LLP

Developments in Association Law 2022 – 2024

The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more

Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

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The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Kohn, Kohn & Colapinto LLP

Supreme Court Vacates and Remands IRS Tax Whistleblower Case Following Reversal of Chevron

The end of the Chevron deference is already impacting whistleblower award cases. The Supreme Court of the United States (SCOTUS) recently reversed and remanded an appeals court decision in an IRS whistleblower case where a...more

McDermott Will & Emery

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

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On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Fenwick & West LLP

Five Tax Cases that May Impact Your Business 2024

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The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more

Kohrman Jackson & Krantz LLP

Move Over TikTok, the Tax Man May Be Snooping on You, Too

In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more

Snell & Wilmer

Arizona Taxation of Tribal Work Performed Under Federal Contracts Upheld by U.S. Supreme Court Precedent

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A three-panel Arizona Court of Appeals ("the panel”) unanimously ruled on January 10, 2023, that, under U.S. Supreme Court precedent, the gross proceeds from work performed under federal contracts on Native American...more

McDermott Will & Emery

Supreme Court to Consider Whirlpool’s Petition for Certiorari in Significant Subpart F Case

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On August 10, 2022, a petition for writ of certiorari filed by Whirlpool Financial Corporation & Consolidated Subsidiaries and Whirlpool International Holdings S.a.r.l. & Consolidated Subsidiaries (collectively, Whirlpool)...more

McDermott Will & Emery

Will the Supreme Court Rule on Whirlpool’s Subpart F Income Case?

A war is currently waging in the tax world over when courts should give deference to the US Department of the Treasury’s regulations. (We have written extensively on this subject...) However, another potential war looms: Can...more

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

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Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

McDermott Will & Emery

Late CDP Petitions May Still Be Entitled to Tax Court Review

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In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Boechler, P.C. v. Commissioner of Internal Revenue

On April 21, 2022, the U.S. Supreme Court decided Boechler, P.C. v. Commissioner of Internal Revenue, No. 20-1472, holding that the 30-day period to petition for review of an IRS Independent Office of Appeals’ decision is a...more

Freeman Law

Supreme Court Update on Tax Cases (March 1, 2022)

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Multiple federal tax cases continue to make their way to the U.S. Supreme Court, and it has certainly been interesting to monitor changes and updates to the Court’s docket. I previously wrote a blog on the oral arguments held...more

Freeman Law

CDP Proceedings—Is the Time Limit in Section 6330(d)(1) a Jurisdictional Requirement for Tax Court Petitions?

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In the tax universe, deadlines are normal and expected. Most Americans are familiar with income tax filing deadlines (e.g., April 15th), and businesses are familiar with employment tax deadlines (e.g., January 15th)....more

McDermott Will & Emery

A Look Back at Supreme Court Justice Breyer's Tax Opinion in Home Concrete

On January 27, 2022, Supreme Court of the United States Justice Stephen Breyer formally announced his retirement, effective when the Supreme Court breaks for summer recess in June or July later this year—after his successor...more

Venable LLP

Should Your Lawyer Be a Grammar Nerd?

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Sometimes, yes. At least that’s one takeaway from the argument in a recent U.S. Supreme Court case, Boechler, P.C. v. Commissioner of Internal Revenue. ...more

McDermott Will & Emery

Supreme Court Grants Certiorari in One Tax Case, Denies it in Several Others

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Historically, the Supreme Court of the United States rarely grants petitions for certiorari in tax cases, and it appears this trend continues in the current term. On September 30, 2021, the Supreme Court granted the...more

Farrell Fritz, P.C.

The Biden Presidency: How Will Cannabis Business Be Taxed?

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Wither the Weed? It has been one month since Mr. Biden’s inauguration as President of the United States. Among the many questions being asked of President Biden is whether he will seek the decriminalization of cannabis....more

King & Spalding

Trade & Manufacturing - News of Note - July 2019

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U.S. Senators Call For Treasury To Raise Taxes On French Interests In Response To Potential Digital Services Tax - On June 24, 2019, the U.S. Senate Finance Committee, through its Chairman Chuck Grassley (R-IA) and...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

McDermott Will & Emery

Focus on Tax Controversy - Fall 2014

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Supreme Court to Hear Tax Injunction Act Case - On August 20, 2013, in Direct Marketing Association v. Brohl, the U.S. Court of Appeals for the Tenth Circuit held that the federal Tax Injunction Act (TIA) prohibited...more

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