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Tax Appeals Supreme Court of the United States

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

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

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

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

Miller Canfield on

Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

Morrison & Foerster LLP

New York Residents Don’t Wynne?

The New York Appellate Division, First Department held that the U.S. Supreme Court’s 2015 decision in Comptroller v. Wynne does not render New York’s statutory residency scheme unconstitutional and upheld the dismissal of the...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 6

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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