News & Analysis as of

Statutory Interpretation Internal Revenue Service Tax Court

Fenwick & West LLP

Rawat Creates a Ripple in Statutory Interpretation Principles

Fenwick & West LLP on

Recently, in Rawat v. Commissioner, the D.C. Circuit reversed the Tax Court decision and held that a foreign partner would not be subject to U.S. tax on selling an interest in a partnership with “hot assets” subject to §...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

McDermott Will & Emery on

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

Freeman Law

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

Freeman Law on

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

Miller Canfield

Disregarding Administrative Tax Guidance Aided the IRS in Two Cases and the Taxpayer in a Third Case

Miller Canfield on

​​​​​​​Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable. The...more

Miller Canfield

Tax Court Decision in Little Sandy Coal Co. is Based on an Erroneous Statutory Interpretation and Should Be Reversed in the...

Miller Canfield on

The taxpayer in Little Sandy Coal Co. v. Commissioner, T.C. Memo 2021-15 (Feb. 11, 2021) has appealed an unfavorable United States Tax Court decision to the United States Court of Appeals for the Seventh Circuit. The decision...more

Venable LLP

Should Your Lawyer Be a Grammar Nerd?

Venable LLP on

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

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