Jones Day Presents: LB&I Examination Strategies: Process Overview
Podcast: Cum-Ex Dividend Trade Investigations
Supreme Court’s Rulings On Same-Sex Marriage Spark Many Questions On Employee Benefits
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
Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary: Eric Schwartz (“Schwartz”) and his spouse divorced. Pursuant to those divorce proceedings, the state court...more
Three months on from the Supreme Court’s decision in McGirt v. Oklahoma, the fallout is becoming increasingly clear in Oklahoma. On July 9, 2020, the Supreme Court issued its opinion in McGirt, ruling that most of the eastern...more
In its recent decision in Rodriguez v. Federal Deposit Insurance Corp., No. 18–1269 (Sup. Ct. Feb. 25, 2020), the Supreme Court held that federal courts may not apply the federal common law “Bob Richards Rule” to determine...more
On February 25, 2020, the United States Supreme Court in Rodriguez v. Federal Deposit Insurance Corporation struck down a judicial federal common law rule—known as the Bob Richards rule—that is used by courts to allocate tax...more
On February 25, 2020, in Rodriguez v. Federal Deposit Insurance Corporation, No. 18-1269 (U.S. 2020), the U.S. Supreme Court effectively ruled that the so-called “Bob Richards rule” should not be used to determine which...more
On February 25, 2020, the United States Supreme Court issued a unanimous opinion vacating a decision by the U.S. Court of Appeals for the Tenth Circuit applying federal common law to determine the allocation of a corporate...more
The United States Supreme Court has picked up the pace this week, already issuing eight regular opinions and four opinions relating to orders as of today. We discuss the tax-related items here. In Rodriguez v. FDIC, the...more
On February 25, 2020, the Supreme Court decided Rodriguez v. Federal Deposit Insurance Corporation, No. 18-1269, overruling a federal common law rule that was used in some circumstances to determine how to distribute the tax...more
When can a Federal Court employ a federal common law rule to make its decision in the case? Justice Gorsuch answer this in Rodriguez v. Fed. Deposit Ins. Corp., U.S., No. 18-1269, 2/25/20. The answer...less often than you...more
Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more
In an important win for taxpayers, a unanimous Second Circuit reversed the Tax Court on a statutory interpretation issue involving the three-year “look-back” period for Tax Court jurisdiction over refunds. Borenstein v....more
In its final ruling of 2014, the Indiana Tax Court held that the Department of Revenue could not wrongly confiscate a taxpayer’s inventory, sell the inventory for pennies on the dollar, and avoid a refund by arguing the Court...more
On September 19, 2014, the U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds based on foreign tax...more