News & Analysis as of

Administrative Authority Tax Court

Eversheds Sutherland (US) LLP

Tax Court holds final partnership adjustment untimely, invalidates conflicting regulation

On July 2, 2025, the Tax Court issued its unanimous reviewed opinion in JM Assets, LP v. Commissioner, 165 T.C. 1. It held that the Service did not timely issue a final partnership adjustment (FPA) to JM Assets, LP (JM...more

Allen Matkins

Does One State Agency Have The Power To Declare Another State Agency's Regulation To Be Invalid?

Allen Matkins on

As a former teacher of Administrative Law, I am interested in a recent request to the California Attorney General for an opinion whether the California Office of Tax Appeals has the authority to declare  regulations adopted...more

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