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
Shortly after oral arguments on the correct standard for assessing the application of mixed-purpose communications in In re Grand Jury, the U.S. Supreme Court dismissed its writ of certiorari as improvidently granted. To...more
Today, the United States Supreme Court issued a "non-decision" in In re Grand Jury. The case involved a conflict among federal circuit courts of appeal over which legal test should be applied to evaluate whether so-called...more