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Saturday, April 18, 2026

District Court Invalides and Vacates Listed Transaction Reporting Regulation (4/18/26)

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In Drake Plastics Ltd. Co. v. IRS , ___ F. Supp. 3d ___ (S.D. Tex. 4/15/26), CL here , and GS here [to come], the court (Judge Lee Rosenthal...
Monday, April 13, 2026

Microsoft Copilot AI Hallucinates on Chevron Deference (4/12/26)

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I have previously written on artificial intelligence (“AI”) related to tax procedure issues. I write today to address AI hallucinations of t...
Saturday, April 4, 2026

Tax Court Sustains Deficiencies Equaling Restitution with No RBA (4/4/26)

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In  Thody v. Commissioner , T.C. Memo. 2026-30, the Court sustained the deficiencies asserted against Thody with respect to the tax loss tha...
Thursday, April 2, 2026

Court Denies Charity's Motion to Dismiss a Suit to Judicially Extinguish a Conservation Easement Deduction Failing to Achieve a Tax Deduction (4/2/26)

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Today’s entry arises from an order in a case where the Petitioner, as successor in interest to three LLCs that made so-called charitable con...
Wednesday, April 1, 2026

Prominent Convicted Tax Shelter Lawyer Fails on Appeal in CDP Case Involving Restitution Based Assessments (4/1/26)

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  I start with a caveat: although this posting is on April 1, sometimes called April Fools Day, this is intended as a serious discussion. In...
Tuesday, March 31, 2026

The Economic Substance Doctrine ("ESD")--the Common Law and § 7701(o) (3/31/26; 4/8/26)

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In Royalty Management Ins. Co., Ltd. v. Commissioner , T.C. Memo. 2026-26 (T.C. No. 3823-19, here, at #338 and GS here ), Judge Lauber smack...
Monday, March 30, 2026

Tax Court (Judge Lauber) Strikes Down Another Bullshit Tax Shelter Not Defending It's Return Reporting Valuation (3/30/26; 4/2/26)

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In Hancock County Land Acquisitions, LLC v. Commissioner , T.C. Memo. 2026-28, TC here at # 232 and GS here , Judge Lauber shot down anothe...
Monday, March 23, 2026

Déjà vu All Over Again-Non SCE Tax Shelter with Alleged Bullshit SCE Features (3/23/26)

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Bloomberg has this article: Michael J. Bologna, Whistleblower Targets Tax Shelter Promoting Do-Good Technology (Bloomberg Tax 3/23/26), her...
Wednesday, March 18, 2026

Update on FTPB Discussion of Legislative History (3/18/26)

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I have substantially revised the legislative history discussion in my Federal Tax Procedure Working Draft for the 2026 editions (Student an...
Saturday, March 7, 2026

Comments on Highly Recommended Article Extending Skidmore "Deference" Approved in Loper Bright (3/7/26; 3/8/26)

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I have just read a great article: Mitchell Zaic, Note: The Skidmore Compromise: Interpreting Skidmore as a Tiebreaker to Preserve Judicial W...
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