News & Analysis as of

Loper Bright Enterprises v Raimondo Internal Revenue Service Judicial Review

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

Davies Ward Phillips & Vineberg LLP

U.S. Supreme Court Upends 40 Years of Judicial Deference to Regulations

In a historical opinion in Loper Bright Enterprises v. Raimondo, Secretary of Commerce, released at the end of June, the U.S. Supreme Court overturned the “Chevron” doctrine, which for so long had controlled judicial review...more

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