News & Analysis as of

Jurisdiction Income Taxes Tax Liability

Hone Maxwell

Supreme Court Gives IRS Ability to Levy Taxpayers Without Tax Court Challenge

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In a pivotal ruling, the U.S. Supreme Court on June 12, 2025, held that the U.S. Tax Court lacks jurisdiction to hear a taxpayer’s Collection Due Process appeal under IRC § 6330 once the IRS can no longer pursue a levy,...more

DLA Piper

Chile: Actualización de los Regímenes Fiscales Preferenciales

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El Servicio de Impuestos Internos (SII) publicó la resolución exenta N°30, que contiene la nómina actualizada de territorios o jurisdicciones que poseen un régimen fiscal preferencial, conforme a los criterios de la nueva...more

DLA Piper

Chile Updates its List of Preferential Tax Regimes

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The Chilean Internal Revenue Service (SII) has published its Exempt Resolution N°30, which updated the list of territories or jurisdictions that qualify as preferential tax regimes according to the criteria of the new rule....more

Freeman Law

Tax Court in Brief | XC Foundation v. Comm’r | Tax Court Jurisdiction and Corporate Capacity to Seek Relief

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Summary: XC Foundation (“XC”) was incorporated in California in 2007. In 2008, the IRS issued XC a determination letter recognizing it as exempt from federal income tax under section 501(c)(3) and as a private foundation...more

Freeman Law

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

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Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary:  Eric Schwartz (“Schwartz”) and his spouse divorced.  Pursuant to those divorce proceedings, the state court...more

Freeman Law

A Win for Taxpayers—Section 6330(d)(1) is a Nonjurisdictional Deadline

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Collection Due Process Hearings and Jurisdiction Collection Due Process (“CDP”) hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals before...more

Freeman Law

Tax Court in Brief | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

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Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

Freeman Law

The Tax Court in Brief - December 2021 #4

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Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L - Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more

Freeman Law

The Tax Court in Brief - December 2021

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Tax Litigation: The Week of December 6 – December 10, 2021 - Coggin v. Comm’r, 157 T.C. No. 12 | December 8, 2021 | Weiler, J. | Dkt. No. 21580-19 - Short Summary: Alice J. Coggin (“Coggin”), who was married during...more

Williams Mullen

“Sure, You Can Work Remote”...These Words May Have a Huge Cost...

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COVID has not only seen a migration of employees to remote work but has created a new business model that is here to stay. In the midst of COVID, employers were eager to allow their employees to work from home and maintain a...more

Freeman Law

The Tax Court in Brief - August 2021 #5

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Tax Litigation: The Week of August 23 – August 27, 2021 - Tax Court Case: Estate of Charles P. Morgan, Deceased, Roxanna L. Morgan, Personal Representative and Roxanna L. Morgan v. Comm’r, T.C. Memo 2021-104 | August 23,...more

Freeman Law

Recent Bankruptcy Court Ruling Addresses the Jurisdiction of Bankruptcy Courts to Hear Innocent Spouse Relief Cases

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The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more

Freeman Law

The Tax Court in Brief - July 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of July 5 – July 9, 2021 - Peterfreund v. Commissioner,...more

Freeman Law

The Tax Court in Brief

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of October 31 – November 6, 2020 - Glade Creek Partners,...more

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