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. September 3, 2026. Airbnb Inc., the online…
In Big Apple Tompkins Realty LLC v. Commissioner, 167 T.C. No. 7 (2026), the Tax Court held that the 90-day filing deadline in section 6234(a) was…
If a taxpayer has a “substantial understatement” of income tax, the Internal Revenue Service (“IRS”) can assert a penalty. In fact, the IRS’s default procedure is…
Recently, the Tax Court issued a memorandum opinion in Paschall v. Commissioner, T.C. Memo. 2026-46, holding that the cryptocurrency proof-of-stake rewards at issue in that case…
Open letter to Mr. Taxpayer Mr. Taxpayer, you quit too soon. Perhaps you were worn down by the prison sentence for willful failure to file tax…
The Fourth Circuit holds that the plain language of the innocent spouse statute (IRC § 6015(f)(1)) means that underpayment interest the IRS erroneously refunded is a…