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Tax Liability Administrative Procedure Act Government Agencies

Snell & Wilmer

California Office of Tax Appeals Cleared To Consider Whether Tax Regulations Conflict With Statutes

Snell & Wilmer on

The California Attorney General (AG) recently issued Legal Opinion No. 23-701 stating that the California Office of Tax Appeals (OTA) has the authority to determine whether tax regulations issued by the Franchise Tax Board...more

Fox Rothschild LLP

Ruling Allows IRS to Automate Review of Employee Retention Credit Claims

Fox Rothschild LLP on

A federal court has upheld the IRS’s right to use automated tools to review Employee Retention Credit (ERC) claims, rejecting a challenge brought by two tax preparation firms. In ERC Today LLC v. McInelly, the U.S. District...more

McDermott Will & Schulte

The Employee Retention Credit: IRS’s “Risking” Model Faces Legal Challenge

Case: ERC Today LLC et al. v. John McInelly et al., No. 2:24-cv-03178 (D. Ariz.) In an April 2025 order, the US District Court for the District of Arizona denied a motion for a preliminary injunction filed by two tax...more

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