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Thursday, February 27, 2025

Updates on Filing under the Corporate Transparency Act (“CTA”) (2/27/25; 3/4/25)

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Added 3/4/25 10:00 am: Please note below that, on March 2, 2025, Treasury announced here that  (i) Treasury will not enforce penalties or f...
Wednesday, February 26, 2025

Tax Court Sustains Regulation's Filling Gap in Statute on Factors Other than Ambiguity (2/26/25/ 3/4/25)

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In Hamel v. Commmissioner , T.C. Memo. 2025-19 ( Hamel II ), TN here , GD here  * and GS here **, decided 2/25/25, upon reconsideration of ...
Thursday, February 20, 2025

Bullshit Tax Shelter "Investors" Reach the End Game on Tax Dodging from 1999 BLIPS "Transaction" (2/20/25)

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Yesterday, the Tax Court (Judge Goeke) entered its opinion in Blum v. Commissioner , T.C. Memo. 2025-18, TN here , GD here *, and GS here **...
Tuesday, February 18, 2025

Final Paper on SSRN Titled: Loper Bright Is the Law But Poor Statutory Interpretation (2/28/25)

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Today, I finalized a paper which has been posted to SSRN. The posting is here: John A. Townsend, Loper Bright Is the Law But Poor Statutor...
Saturday, February 15, 2025

The Relation of the Current DOJ Commotion to Loper Bright (2/15/25)

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Readers have undoubtedly heard of the commotion about the DOJ order to the prosecutors in the U.S. Attorney’s Office in SDNY to dismiss the ...
Tuesday, February 11, 2025

Agency Interpretations, Bell Curves, and Skidmore ooomph under Loper Bright (2/12/25)

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Professor Christopher Walker, here , a frequent commentator on administrative law and on deference under Chevron and Loper Bright , has off...
Monday, February 3, 2025

Prominent Senate Finance Committee Members Offer Discussion Draft of Bill to Fix Certain IRS Procedure and Administration Issues (2/2/25)

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Note to Readers: This blog entry was posted yesterday to a page rather than a blog page. I have moved it to the blog page. I will leave the...
Thursday, January 30, 2025

Tax Court Rejects Constitutional Challenges to Appeals Office CDP Participation (1/30/25)

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In Tooke v. Commissioner , 164 T.C. ___, No. 2 (1/29/25), here * and GS here **, the Court, in a CDP case, rejected taxpayer arguments that...
Friday, January 24, 2025

Schwarzbaum Redux – 11th Circuit Issues New Opinion to Correct Statement of FBAR Willfulness Civil Penalty Standard (1/23/25)

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 In  United States v. Schwarzbaum , ___ F.4th ___ (11th Cir. 1/23/25), CA11  here  and GS here , the 11 th  Circuit revisited the long-runni...

Supreme Court Stays District Court Injunction Against Filing Requirements of Corporate Transparency Act (1/24/25; 1/26/25)

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Corporate Transparency Act Case Overview The first Corporate Transparency Act ("CTA") case to reach the Supreme Court involved a...