Jurisdiction, Internal Revenue Code (IRC), Income Taxes

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

Hone Maxwell on 6/26/2025

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

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

Freeman Law on 1/10/2023

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

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

Freeman Law on 5/3/2022

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

The Tax Court in Brief - December 2021 #4

Freeman Law on 1/21/2022

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

The Tax Court in Brief - December 2021

Freeman Law on 1/7/2022

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

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

Freeman Law on 8/12/2021

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

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

McDermott Will & Schulte on 4/16/2019

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

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