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Appeals › Tax Court › Tax Refunds

Lippes Mathias LLP

Supreme Court Undermines Taxpayers’ Due Process Rights

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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

McDermott Will & Schulte

IRS Roundup February 10 – 14, 2025

McDermott Will & Schulte on

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

McDermott Will & Schulte

Taxpayer Loses Claim for Research Credit

McDermott Will & Schulte on

In United States v. Grigsby, Docket No. 22-30764, the US Court of Appeals for the Fifth Circuit held that a refund claim based on claimed Internal Revenue Code (IRC) Section 41 credits was erroneous. Cajun Industries LLC, a...more

McDermott Will & Schulte

With the IRS, Mail Delivery Counts!

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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

Lathrop GPM

Tax Court Confirms Constitutionality of Minnesota Estate Tax

Lathrop GPM on

On December 12, 2022, the Minnesota Tax Court released an opinion in Estate of Anderson v. Commissioner of Revenue addressing the constitutionality of Minnesota’s estate tax structure as applied to an estate that consisted...more

McDermott Will & Schulte

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

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Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more

Eversheds Sutherland (US) LLP

The Second Circuit - canons of construction prevail in dizzying case of “black hole” tax refunds

Eversheds Sutherland (US) LLP on

In an important win for taxpayers, a unanimous Second Circuit reversed the Tax Court on a statutory interpretation issue involving the three-year “look-back” period for Tax Court jurisdiction over refunds. Borenstein v....more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

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