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Statutory Interpretation Internal Revenue Service Tax Appeals

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

Cozen O'Connor

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

Cozen O'Connor on

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

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

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

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