News & Analysis as of

Statutory Interpretation Internal Revenue Code (IRC) Appeals

Eversheds Sutherland (US) LLP

In Rawat, DC Circuit construes the Code and regulations without deference, providing an example of statutory and regulatory...

On July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more

McDermott Will & Emery

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

McDermott Will & Emery on

Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more

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