In this article, we discuss some basic considerations for preparing a protective refund claim. These considerations are particularly relevant for taxpayers whose statutes of limitations for refund claims are expiring soon and...more
On June 26, 2023, the Supreme Court of the United States agreed to hear a rare challenge under the Sixteenth Amendment and Tax Clauses to Section 965 of the tax code. In Moore v. United States, the justices will consider...more