News & Analysis as of September 12, 2025

Tax Appeals

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Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period usually commencing from the date of the wrong or injury or the discovery of the wrong or injury. Except for under a limited set of circumstances, if an individual does not file a suit within the specified time period, the law bars them from ever suing on that claim. less -

Exception to General Refund Limitations Period for PA Corporate Net Income Tax for Report of Change

Cozen O'Connor on 9/9/2025

In an unusually taxpayer-friendly decision, a three judge panel of the Pennsylvania Commonwealth Court concluded that Section 406 of the Tax Reform Code of 1971 (the code), 72 P.S. § 7406, is an exception to the general...more

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

Rivkin Radler LLP on 10/31/2024

Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

MoFo New York Tax Insights - Volume 7, Issue 6

Morrison & Foerster LLP on 6/8/2016

New York City Tribunal Rejects City’s Attempt To Forcibly Combine Bank And Its Mortgage Subsidiary - The New York City Tax Appeals Tribunal, affirming a determination of the Chief Administrative Law Judge, has held that...more

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Statute of Limitations › Audits › Tax Appeals

Exception to General Refund Limitations Period for PA Corporate Net Income Tax for Report of Change

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

MoFo New York Tax Insights - Volume 7, Issue 6

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