New FLSA Notice Standard, DOL’s PAID Program, Axed Wage and Hour Penalties - #WorkforceWednesday® - Employment Law This Week®
False Claims Act Insights - Beyond Adversarialism: How to Steer FCA Investigations
Hospice Insights Podcast - Hospice Audit Updates: Hospices Fare Well in Federal Court
Nationwide FLSA Lawsuits Just Got Harder—Here’s Why - #WorkforceWednesday® - Employment Law This Week®
Daily Compliance News: August 1, 2025, The All AI Edition
The Journey of Litigation
Quick Guide to Administrative Hearings
Wire Fraud Litigants Beware: Fourth Circuit Ruling Protects the Banks — The Consumer Finance Podcast
Solicitors General Insights: The Tale of Two Washingtons — Regulatory Oversight Podcast
How confidential is a request to access or challenge information in INTERPOL’s files?
Understanding the Impact of IPR Estoppel and PTAB Discretionary Denials — Patents: Post-Grant Podcast
The Presumption of Innocence Podcast: Episode 64 - Cages We Built: The Making of Mass Incarceration in America
Solicitors General Insights: The Legal Frontlines in Iowa and Indiana — Regulatory Oversight Podcast
(Podcast) The Briefing: The Ninth Circuit Puts the Brakes on Eleanor’s Copyright Claim
The Briefing: The Ninth Circuit Puts the Brakes on Eleanor’s Copyright Claim
(Podcast) The Briefing: No CTRL-ALT-DEL For the Server Test
The Briefing: No CTRL-ALT-DEL For the Server Test
Navigating PTAB’s New Approach to IPR and PGR Discretionary Denial - Patents: Post-Grant Podcast
Solicitors General Insights: A Deep Dive With Mississippi and Tennessee Solicitors General — Regulatory Oversight Podcast
Update on the State of Non-compete Restrictions (LaborSpeak)
In prior posts, I discussed the dangers of playingBattleship with the IRS and how taxpayers scored “a hit”. Recently, taxpayers took another turn in the game and scored another hit with the District Court’s recently issued...more
Discussions of the tax-exempt status of universities, nonprofit advocacy groups and other Section 501(c)(3) organizations frequently have been in the news lately. The IRS revocation of a Section 501(c)(3) organization's...more
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more
On May 28, 2025, the United States Tax Court held that the limited partners of a limited partnership providing investment management services to various investment funds were not limited partners within the meaning of...more
Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...more
On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more
Denham Capital Management LP (“Denham”), a private equity firm, has appealed the recent U.S. Tax Court decision that declined to revisit its interpretation of the “limited partner exception” under the Self-Employment...more
On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a taxpayer-friendly legislative proposal. While it is uncertain whether the TAS Act...more
On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more
On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more
In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more
On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more
On October 28, the US Court of Appeals for the Fifth Circuit held that a nonprofit corporation that coordinates health care for privately insured patients does not qualify for tax exemption under Section 501(c)(4) because it...more
The US Supreme Court recently issued a significant decision, impacting many closely-held businesses with buy-sell agreements funded by life insurance policies, Connelly v. United States, 144 S. Ct. 1406 (2024). In a 9-0...more
An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more
On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
On July 19, 2023, the United States Court of Appeals for the Third Circuit released an opinion in the matter of Culp v. Commissioner of Internal Revenue (PDF). The ruling stated the 90-day filing period for Tax Court...more
Over the years, case law has developed around when a mail delivery method is acceptable to prove that a tax filing was made. The US Court of Appeals for the Fourth Circuit’s recent decision in Pond v. United States[1] ...more
Overview - Most of you know that I am a big music fan. I have always liked Joe Cocker. The song The Letter is a song that was originally performed by The Box Tops and was a Number 1 hit in 1967. The song was covered by Joe...more
The Internal Revenue Service Independent Office of Appeals (IRS Appeals) is the administrative forum for taxpayers to attempt to resolve tax disputes prior to litigation. Subject to certain exceptions, taxpayers can file a...more
Since Chai v. Commissioner, an opinion by the US Court of Appeals for the Second Circuit subsequently followed by the US Tax Court in several opinions, there has been a substantial number of cases litigating issues involving...more
In 2017, we posted about the IRS Independent Office of Appeals’ (IRS Appeals) implementation of a face-to-face virtual option for taxpayers. Now, IRS Appeals wants suggestions from tax professionals on how to improve and...more