Expert Report Requirements of Tax Court Rule 143(g) Do Not Apply to Declarations in Support of Pre-Trial Discovery Motions September 3, 2026
Tax Court Jurisdiction in Late-Filed Petition in a BBA Partnership Case and Burden of Proof August 6, 2026
IRS Phaseout of the First Time Penalty Abate (FTA) Program to be Replaced by the Automatic Exemption from Penalty (AEP) Procedure July 15, 2026
MFA Boston’s Transfer of an Enslaved Potter’s Art to a Trust for His Descendants Raises Questions about Tax Basis July 14, 2026
Payments to Charity After Enactment of OBBBA Floors: Business Expense or Charitable Contribution? June 30, 2026
Another Charitable Deduction Disallowed Because the Gift Letter Failed to Satisfy the Strict Substantiation Requirements June 15, 2026
Filing a Claim with the IRS for a Refund or Abatement of Interest and Penalties that Accrued During the COVID-19 Pandemic – Section 7508A(d), Abdo, and Kwong June 4, 2026
The Playbook for Moving on from Citing Nonexistent Cases Hallucinated by Artificial Intelligence (AI) May 24, 2026
Reversal of Tax Court Ruling on Interest Erroneously Paid Allows for Consideration of Equitable Relief Under the Innocent Spouse Statute May 22, 2026
Failure to Substantiate Charitable Contribution with a Proper Gift Letter Results in No Deduction May 20, 2026
How the IRS’s Fourth Program to Settle Syndicated Conservation Easements Compares to the Earlier Settlement Programs May 18, 2026
Van Gogh’s “Olive Picking”, Alleged Art Trafficking, and the Special Tax Rules for Victims of the Nazi Regime March 26, 2026
Can an OIC for Effective Tax Administration Make Right the IRS’s Erroneous Rebate Refund? February 19, 2026
