Federal
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September 24, 2026
IRS Finalizes Increase In Estate Tax Closing Letter Fee
The Internal Revenue Service finalized a $76 fee for taxpayers to request a letter that confirms the agency has received and finished examining an estate tax return, increasing the fee from $56, according to a final rule released Thursday.
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September 23, 2026
Goldstein Not Leaving Prison Any Time Soon, 4th Circ. Rules
The Fourth Circuit balked late Wednesday at freeing Tom Goldstein from prison as he fights felony convictions, and it rejected fast-track review of the renowned appellate advocate's trial, indicating he'll likely spend substantial time behind bars even if his appeal succeeds.
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September 23, 2026
Overseas Income Regs May Cause M&A Headaches
Regulations proposed by the U.S. Treasury Department would provide clean breaks for companies that sell more than 50% of their foreign affiliates, but transactions that fall below this threshold could still expose corporations to post-closing tax risks and deal friction.
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September 23, 2026
Fla. Couple Did Not Properly Back Deductions, Tax Court Says
A Florida couple failed to properly substantiate reported tax deductions, including claims to property damage from a 2018 hurricane, items donated to charities and travel expenses, the U.S. Tax Court said Wednesday, ruling the taxpayers had underreported their income.
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September 23, 2026
Home Health Co. Asks Tax Court To Invalidate IRS Levy
An in-home health company is not liable for nearly $236,000 in civil penalties imposed by the Internal Revenue Service, it told the U.S. Tax Court, urging it to determine that the agency's proposed levy action should not have been sustained.
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September 23, 2026
Aventis Denies Owning Assets In $40M Tax Fight At 3rd Circ.
The U.S. Tax Court contradicted its own findings by deciding that pharmaceutical company Aventis controlled assets in an investment vehicle with a French affiliate, couldn't deduct related payments and was liable for nearly $40 million in income taxes, the company told the Third Circuit.
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September 23, 2026
Judge Dismisses Son's Bid To Recoup Parents' Tax Payments
A Tennessee federal judge dismissed a son's bid for a refund of federal income taxes for his dead parents' estates, finding he failed to establish that his father sufficiently participated in an amusement equipment manufacturing business to claim associated losses.
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September 22, 2026
IRS Requests Comments On Proposed Opportunity Zone Regs
The Internal Revenue Service on Tuesday requested comments on the implementation of the federal opportunity zone program, including whether additional guidance is needed to address issues related to opportunity fund investment.
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September 22, 2026
Atty Urges 4th Circ. To Reverse Liability For Client's Taxes
A Baltimore attorney asked the Fourth Circuit to reverse a lower court's order that he cover unpaid federal income taxes owed by his client's holding company, saying he didn't engage in self-dealing.
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September 22, 2026
8th Circ. Asked To Nix Fraud Tax Credit Suit, $90M Judgment
A man accused of helping form a sham limited liability company that fraudulently received millions in alternative fuel mixture tax credits asked the Eighth Circuit on Tuesday to reverse a judgment of more than $90 million against him, saying he shouldn't be personally liable for the company's conduct.
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September 22, 2026
US Asks 5th Circ. To Revive IRS Deal On Church Politicking
The U.S. government urged the Fifth Circuit to revive its deal with four religious groups to allow churches to engage in some political speech without losing their tax-exempt status, saying a lower court improperly dismissed the case in its entirety for lack of jurisdiction.
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September 22, 2026
Tax Court OKs $21M Easement Cut In Appeal Process Fight
The IRS did not wrongfully deny a holding company the chance to appeal a reevaluation that lopped $21 million off the value of a Tennessee conservation easement for which it claimed a deduction, the U.S. Tax Court ruled Tuesday.
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September 22, 2026
Dispensary's Tax Deduction Properly Nixed, IRS Tells 9th Circ.
The U.S. Tax Court correctly ruled that a San Francisco marijuana dispensary's expenses found to be tied to trafficking in controlled substances aren't deductible, the IRS told the Ninth Circuit, saying such a deduction shouldn't be allowed in determining an amount to settle the business's $3 million tax debt.
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September 22, 2026
Virgin Islands Tax Agency Can't Ignore Treasury, Judge Says
The U.S. Supreme Court's 2024 Loper Bright decision does not allow U.S. Virgin Islands revenue collectors to override U.S. Treasury Department regulations exempting residents of the territory from the net investment income tax, a federal judge held.
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September 21, 2026
Xbox Buyer Says IEEPA Refund Arbitration Bid Lacks Backing
Microsoft's bid to force arbitration of an Xbox purchaser's proposed class action accusing the video game giant of wrongfully withholding tariff refunds from consumers should fail because it can't point to a clause that covers his dispute, he told a Washington federal court.
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September 21, 2026
IRS Properly Nixed Tax Deals, Couple Owe $1.8M, Judge Says
A disbarred lawyer and his wife owe more than $1.8 million in outstanding tax liabilities the IRS has tried to collect for more than a decade, a Wisconsin federal judge said, finding the agency substantiated the liabilities and confirmed that it properly rescinded compromise offers to resolve the debts.
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September 21, 2026
Partnership Was Diligent After Notice Got Lost, Court Says
A partnership's late-filed petition in the U.S. Tax Court was due to circumstances beyond its control in a case where the final partnership adjustment from the IRS was mailed correctly but returned by the U.S. Postal Service as undeliverable, the court held Monday.
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September 21, 2026
IRS Can Enforce Summons In Korean Probe Of VC Partner
The IRS can enforce a summons seeking bank information about a venture capitalist on behalf of South Korean tax authorities, a California federal judge ruled, holding that the statutory requirement to provide advance notice applies only to domestic tax liabilities.
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September 21, 2026
IRS Again Delaying Dividend Anti-Abuse Regs
The IRS is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, the agency announced Monday.
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September 21, 2026
IRS' Economic Substance Doctrine Has Limits, 5th Circ. Told
The IRS should not invoke the economic substance doctrine whenever it dislikes a transaction's tax consequences, an advocacy group told the Fifth Circuit on Monday in an eye doctor and his wife's appeal of a ruling that rejected their ophthalmology practice's microcaptive insurance arrangements.
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September 21, 2026
Varian, Gov't Appeal Foreign Dividend Decision To 9th Circ.
Varian Medical Systems Inc. is appealing a U.S. Tax Court decision that it owes more than $7.2 million to the Internal Revenue Service as a result of the court limiting its deemed dividends deduction, while the government is also appealing, according to filings in the Ninth Circuit.
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September 21, 2026
IRS Asks 5th Circ. To Pause Microcaptive Rules Case
The IRS asked the Fifth Circuit to stay briefing in a global tax services provider's bid to revive its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a related case before the appeals court.
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September 21, 2026
Funder Says $13M Albania Default Judgment Should Stand
Litigation funder Omni Bridgeway has urged a D.C. federal court to preserve a default judgment enforcing a roughly $13 million arbitral award against Albanian state entities, arguing they waited an unreasonable 18 months to appear despite receiving repeated notice of the case.
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September 18, 2026
Ex-DOJ Chief Lambastes 'Abuses Of Power' In Goldstein Case
The U.S. Department of Justice constantly made false statements in its criminal case against famed appellate advocate Tom Goldstein, and his convictions must be erased because "prosecutorial misconduct pervaded every stage of the proceedings," a former DOJ prosecutor told the Fourth Circuit.
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September 18, 2026
Judge Questions Whether 'Lawfare' Fund Fight Is Really Moot
A Virginia federal judge seemed unlikely to toss a challenge to the Trump administration's nixed "Anti-Weaponization Fund" and tax audit immunity for the Trump family Friday, saying she worries the fund could be revived in a different form down the road.
Expert Analysis
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Mich. Banking Brief: All The Notable Legal Updates In Q2
The second quarter brought several notable financial services law developments to Michigan, including a U.S. Supreme Court ruling on state tax foreclosures, progress on a money transmission modernization bill package, and continued legislative momentum on cryptocurrency and mortgage lending, say attorneys at Dykema.
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Proof, Not Just Timing, Will Decide Clean Energy Credits
For wind and solar projects that sprinted to begin construction before the accelerated placed-in-service deadline of July 4, project owners must now assemble and maintain documentation to qualify the project and defend against a potential clean energy credit audit, says Peter Lowy at Nelson Mullins.
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Choral Singing Makes Me A Better Lawyer
Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.
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Tariff Refunds May Reshape Loan Covenant Calculations
Tariff refunds issued after the U.S. Supreme Court's Learning Resources decision may complicate borrowers' covenant calculations depending on accounting treatment, the timing of recognition, customer reimbursement obligations and credit agreement language, say attorneys at Mayer Brown.
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Power To The Paralegals: Burnout As A Structural Problem
Law firm leadership can best retain their paralegals not by encouraging self-care, but by seeking top-down structural solutions for the quiet proliferation of responsibilities and the vicarious exposure to client trauma that particularly drive burnout in this vital role, says Erika Sneeringer at Brockstedt Mandalas.
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Managing Post-IEEPA Tariff Refunds, Replacements And Risks
Companies and investors reeling from the rapid changes resulting from February's U.S. Supreme Court ruling that the International Emergency Economic Powers Act doesn't authorize tariffs should focus on understanding the duty refund process, the likely replacement tariffs and the operational ways they can minimize their tariff exposure, say attorneys at Debevoise.
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Wire Fraud Ruling May Upend White Collar Enforcement
A Texas federal court’s recent decision in U.S. v. Garza, dismissing wire fraud charges arising from an alleged $1 billion tax shelter scheme, advances a broader constitutional principle that could affect sentencing and reshape charging practices across white collar criminal cases involving specialized statutory regimes, say attorneys at Benesch.
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Economic Questions To Ask Amid Tariff Refund Class Actions
The U.S. Supreme Court's recent holding that the International Emergency Economic Powers Act doesn't authorize the president to impose tariffs has sparked class actions, but determining whether a retailer received a windfall is complex, even if it passed tariff costs into consumer prices before receiving a refund, say economists at Ankura Consulting Group.
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Cow Horse Makes Me A Better Lawyer
Moving an unwilling 800-pound cow while riding a horse at high speed is exhilarating, a little unhinged and, at least for me, a surprisingly effective training ground for litigation — both demand focus, preparation over rigid planning and the willingness to act despite fear, says Ashley Zitrin at Glenn Agre.
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Checking For AI Errors Is Now A Two-Way Street
A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.
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Key Legal Considerations For Data Center Battery Storage
Battery energy storage systems have become essential infrastructure for data center development — but as trade, energy and tax policies continue to shift, companies operating in this space must understand the importance of supply chain requirements and industry-tailored contracts, says RJ Colwell at Davis Graham.