Jurisdiction, Statutory Interpretation, Tax Court

Supreme Court Undermines Taxpayers’ Due Process Rights

Lippes Mathias LLP on 6/30/2025

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

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

The Supreme Court Update - June 12, 2025

Dorsey & Whitney LLP on 6/13/2025

The Supreme Court of the United States issued six decisions today: Parrish v. United States, No. 24-275: This case addresses the procedural requirements for filing a notice of appeal after the original deadline to appeal...more

Should Your Lawyer Be a Grammar Nerd?

Venable LLP on 1/18/2022

Sometimes, yes. At least that’s one takeaway from the argument in a recent U.S. Supreme Court case, Boechler, P.C. v. Commissioner of Internal Revenue. ...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

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

Eversheds Sutherland (US) LLP on 4/5/2019

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