Yesterday the Tax Court issued a bench opinion under IRC § 7459(b) in an underreported income case. The IRS determined the extent to which taxpayers underreported…
This article is substantially similar to the article reprinted from Tax Notes Federal, August 31, 2026. In this article, Kim uses the Tax Court’s recent memorandum…
A recent New York Times article reported that Timothy Mellon, a banking heir, transferred 300 acres of real property to charity. Mellon retained access to certain…
Three years ago, Chariot, the payment and processing company for donor advised funds, declared the second Thursday of October National Donor Advised Funds Day. A few…
Remedy for Alleged Unfair Consideration by IRS Appeals is Court’s De Novo Review, Not Invalidating the Notice A component of the Taxpayer First Act, enacted in…
In Jagannath v. Commissioner, T.C. Memo. 2026-92, the U.S. Tax Court held that a 501(c)(3) organization’s founder owed more than $1.4 million in excise taxes under…
In Daidone v. Commissioner, T.C. Memo. 2026-98, the Tax Court granted summary judgment and held that a requesting spouse was not entitled to innocent spouse relief…
Previously, we explained two cases, Abdo v. Commissioner, 162 T.C. 148 (2024) and Kwong v. U.S., 179 Fed. Cl. 382 (2025), in which courts interpreted section…
The Tax Court weighs in on expert declarations and access to Airbnb’s source code in a multibillion-dollar transfer-pricing dispute. Airbnb Inc., the online marketplace connecting users…
Fair Market Value and the Connection Between Romare Bearden’s Art and August Wilson’s Broadway Play In 1978, renowned artist Romare Bearden created a collage, Mill Hand’s…