News & Analysis as of

Internal Revenue Code (IRC) Supreme Court of the United States Final Rules

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

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

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