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Statutory Interpretation › Income Taxes › Jurisdiction

Rivkin Radler LLP

Responding Timely to A “90-Day Letter” – Is It Jurisdictional?

Rivkin Radler LLP on

In the fictional world of John Wicks, the High Table enforces a strict code of conduct without which the lives of its inhabitants would mimic life in a Hobbesian state of nature. However, as dangerous and as rule-bound as...more

Hone Maxwell

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

Hone Maxwell on

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

McDermott Will & Schulte

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

McDermott Will & Schulte on

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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