June 16, 2026
The U.S. Supreme Court's recent decision upholding federal agency fines without a jury trial doesn't undermine a challenge against IRS penalties tied to a charitable tax deduction for a Louisiana conservation easement contribution, the partnership donor told the Fifth Circuit.
March 16, 2026
The Internal Revenue Service violated the Seventh Amendment by imposing civil fraud penalties without a jury first reviewing them, a partnership told the Fifth Circuit, arguing the penalties' common-law roots allow the entity to invoke constitutional protections in its conservation easement tax deduction dispute.