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Statutory Interpretation Internal Revenue Service Tax Refunds

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

Lippes Mathias LLP

Supreme Court Undermines Taxpayers’ Due Process Rights

Lippes Mathias LLP on

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

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