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Federal
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May 06, 2026
IRS To Settle More Syndicated Easement Disputes
Eligible partnerships may soon be able to settle their disputes with the IRS over charitable tax deductions claimed on their donated conservation or historic preservation easements under an upcoming "time-limited" opportunity, the agency announced Wednesday.
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May 06, 2026
4th Circ. Appears Unpersuaded By $22M Tax Fraud Appeal
Two attorneys and an insurance agent faced a Fourth Circuit panel Wednesday that seemed hard-pressed to overturn their convictions for orchestrating a $22 million tax avoidance scheme, with the judges casting doubt on their venue objections and claims that the false tax returns contained truthful information.
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May 06, 2026
IRS Gets Protest Of Wedding Gift Penalties Narrowed
A Chinese citizen seeking a refund of penalties imposed by the IRS over a failure to report wedding gifts she received from abroad cannot argue the agency must collect the penalties through a civil action, a California federal court said, partially dismissing her suit.
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May 06, 2026
Insurers Ask To Ignore Simplified Foreign Currency Rules
The insurance industry should be allowed to ignore regulations from 2024 covering how corporations determine taxable income with respect to affiliates that conduct business in a foreign currency, the American Council of Life Insurers told the U.S. Treasury in a letter released Wednesday.
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May 06, 2026
Average US Residence Costs $554K, IRS Data Shows
The nationwide average purchase price for U.S. residences in 2026 is $553,900, an increase of $13,200 from last year, according to data the Internal Revenue Service published Wednesday.
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May 06, 2026
Investors Want Puerto Rican Opportunity Zone Safe Harbor
Investors, developers and policy organizations requested clear and timely guidance on the transition protections for existing opportunity zone investments in Puerto Rico before they expire at the end of 2027 in a letter to the U.S. Department of the Treasury released Wednesday.
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May 06, 2026
Extend Immediate Expensing For Plastic Recycling, IRS Told
Advanced plastic recycling should be eligible for a new tax perk allowing full expensing of a qualified production property's costs, a chemical trade association said in a letter, released Wednesday, recommending the industry-specific change for the IRS' upcoming proposed regulations.
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May 05, 2026
Tax Shelter Trial Defendants Claim Promoter Misled Them
More than a dozen lawyers and defendants packed a Colorado federal courtroom Tuesday to mark the first day of testimony in the trial against four individuals accused of using their businesses to help promote and sell abusive trust tax shelters.
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May 05, 2026
IRS Modifies Significant Issue Ruling Program
The IRS outlined the process for taxpayers to request rulings on one or more issues that are solely under the agency's corporate associate chief counsel's jurisdiction that involve certain tax consequences and transactions, according to guidance released Tuesday.
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May 05, 2026
Tax Court Revives Ga. Collections Case Over Notice Flaws
The U.S. Tax Court remanded a Georgia man's collections due process dispute Tuesday, saying that while he "certainly did not facilitate the consideration of his case" with the IRS Office of Appeals, the office improperly failed to consider whether he timely received notices.
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May 05, 2026
Ending Carried Interest Tax Break May Net $88B, Report Says
Ending the carried interest tax break could raise far more than previously estimated, nearly $88 billion in a decade, based on a new methodology put forward in a report by the Yale Budget Lab.
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May 05, 2026
IRS Beats Suit Claiming Secret Rule Targeted Stock Plan
A transportation company cannot pursue its claims that the IRS adopted a secret rule that targeted its stock ownership plan, a Wisconsin federal judge ruled, throwing out the company's suit.
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May 05, 2026
Limited Partners Reject Self-Employment Tax In 1st Circ.
An energy investment company told the First Circuit that its self-employment tax dispute is distinct from that of the taxpayer in a 2009 Federal Circuit ruling that barred refunds to a partnership's individual partners, saying the cases involve different subsections of U.S. income tax law.
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May 05, 2026
Wis. Village Urges 7th Circ. To Void Oneida Tribal Trust Order
A Wisconsin village is asking the Seventh Circuit to undo a U.S. Department of the Interior decision to place 500 acres of properties into trust for the Oneida Nation, arguing that a district court ignored evidence of bias and shielded the transactional record from meaningful scrutiny.
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May 05, 2026
US Ends $15M Tax Refund Fight With Gas Biz Partners
The U.S. government agreed to end litigation alleging that several Texas residents had erroneously claimed a total of about $15 million in tax refunds tied to a partnership involving gas and oil operations in Equatorial Guinea.
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May 05, 2026
IRS To Implement Digital Signatures In Penalty Approvals
The Internal Revenue Service agreed to require supervisors to use digital signatures to approve tax penalties as a way to prevent improper backdating and other edits to the approval documents, the agency watchdog said in a report released Tuesday.
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May 04, 2026
Biz Hit With Extra Penalties For Captive Insurance Deductions
A Florida business must pay additional penalties for deductions taken for microcaptive insurance expenses, the U.S. Tax Court said Monday, backing the IRS' imposition of 40% penalties for tax years 2012 through 2015.
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May 04, 2026
Ex-IRS Agent Accused Of Stealing $12M From Fuel Co.
A former Internal Revenue Service agent was arrested for allegations that he embezzled more than $12 million in his role as a chief financial officer of a New Jersey fuel company, the New Jersey U.S. Attorney's Office said.
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May 04, 2026
Ga. Partnership Defends $46M Deduction For Land Donation
A Georgia partnership defended its claimed deduction of $46 million for 235 acres donated to a land conservation group, saying the IRS wrongly disallowed the amount and determined it underpaid its 2021 taxes by $17 million.
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May 04, 2026
Tax Court Slashes $30M Deductions For Georgia Easements
The U.S. Tax Court slashed two partnerships' charitable tax deductions worth a combined $30 million for a pair of conservation easement donations, ruling Monday that the easements' outsize valuation was an attempt to make "too many fast nickels."
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May 04, 2026
Managers Of Embattled Easement Say RICO Suit Lacks Details
Investment fund managers behind a conservation easement donation whose charitable tax deduction was embroiled in litigation asked a Georgia federal court to toss a racketeering suit against them by a pair of investors, arguing the fraud claims do not match the allegations.
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May 04, 2026
IRS Issues Employer Payment Index For Coverage Penalties
The IRS provided indexing adjustments Monday for calculating penalties against large employers that don't offer health insurance to their full-time workers or whose full-time workers opt to enroll in government-subsidized health coverage using premium tax credits.
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May 04, 2026
IRS Approves Co.'s Retroactive Transfer Pricing Changes
The IRS Office of Chief Counsel has endorsed a company's proposal to reduce certain transfer pricing adjustments through a setoff after retroactively changing how it allocated costs between related companies, according to a memorandum.
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May 04, 2026
Partnership Defends $3M Deduction For Yacht Purchase
A partnership said the IRS wrongly disallowed expenses associated with its boat chartering and fishing tournament activities, including the purchase of a $3 million yacht, during 2020 and 2021, when the COVID-19 pandemic severely disrupted its business.
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May 01, 2026
Biz Group Slams IRS' 'Implicit Support' Argument In Eaton
An international business group urged the U.S. Tax Court to reject IRS arguments that Eaton Corp. deserved a higher credit rating due to its foreign parent's "implicit support," saying the case could significantly affect its members' U.S. tax liabilities.
Expert Analysis
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2 Discovery Rulings Break With Heppner On AI Privilege Issue
While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.
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CBP's $166B Tariff Refund Portal Needs 4 Safeguards
Before launching its automated web portal to process tariff-refund disbursements on April 20, U.S. Customs and Border Protection should apply the expensive lessons learned from the pandemic-era employee retention credit, says Peter Gariepy at RubinBrown.
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How Developers Can Leverage The New Markets Tax Credit
An increased regulatory focus on affordable housing raises important legal considerations for structuring transactions using the oft overlooked New Markets Tax Credit, which can fill a gap in affordable for-sale housing financing by lowering community developer costs but comes with unique compliance, structuring and documentation demands, say attorneys at Stinson.
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Calculating Damages In IEEPA Tariff Refund Litigation
To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.
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Alpine Skiing Makes Me A Better Lawyer
Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.
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What A Court Doc Audit Reveals About Erroneous Filings
My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.
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Mich. Banking Brief: All The Notable Legal Updates In Q1
Michigan's financial services sector saw several significant developments in 2026's first quarter, including the state Department of Insurance and Financial Services' issuance of a bulletin on the use of artificial intelligence and the Michigan House's introduction of a bill based on the Model Money Transmission Modernization Act, say attorneys at Dykema.
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Navigating The Perks Of Qualified Opportunity Zones 2.0
The second iteration of the qualified opportunity zone program, effective Jan. 1, 2027, will introduce new tax incentives for rural real estate development, but these benefits can only be realized if proper governance is a priority, including clear documentation and securities law compliance, says Coni Rathbone at VF Law.
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.
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AI Presents A Make-Or-Break Moment For Outside Counsel
The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.
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8 Tariff Refund Questions For Restructuring Professionals
For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.
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5 Tips For Navigating Your Firm's All-Attorney Summit
Excerpt from Practical Guidance
Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.
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How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs
In light of the U.S. Supreme Court's recent decision striking down President Donald Trump's International Emergency Economic Powers Act tariffs as illegal, some companies may have strong prospects for recovering refunds from the government, and trustees in bankruptcy may have a significant role to play in seeking such recovery, say attorneys at Stinson.