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December 2, 2022
On November 29, 2022, in a unanimous 17-0 opinion in Hallmark Research Collective v. Commissioner, the US Tax Court held that the 90-day time limit is jurisdictional not subject to equitable tolling.
December 2, 2022
Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable...
November 30, 2022
In US v. Weiss, the Third Circuit affirmed a district court’s grant of summary judgment to the government in a suit to collect an individual’s taxes…
November 1, 2022
Scott S. Ahroni is a Lawyer at Polsinelli PC. Ahroni focuses his practice on Federal, State and Local tax controversies.
October 19, 2022
Taxpayers routinely resolve their tax controversy matters without resort to litigation.  Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if...
October 14, 2022
Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, ...
October 5, 2022
Taxpayers routinely resolve their tax controversy matters without resort to litigation. Indeed, good tax professionals will often seek to avoid costly and time-consuming...
September 26, 2022
Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
August 25, 2022
Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may ...
June 24, 2022
Tax Litigation: The Week of June 13th, 2022, through June 17th, 2022 Hatfield v. Comm’r, T.C. Memo. 2022-59 | June 13, 2022 | Lauber, J. | Dkt. Nos. 7327-20, 1500-21 Chavis v. Comm’r,...