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Monday, January 12, 2026

Tax Court Dawson Access to Simultaneous Opening Briefs in Syndicated Conservation Easement (1/12/26)

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Readers of this blog may know that the Tax Court’s Dawson tool shows the docket entries for cases but has historically included for public v...
Thursday, January 8, 2026

Chevron, Loper Bright, and Statutory Ambiguity (1/8/26; 1/9/26)

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Added 1/9/26 9:00pm: I would really appreciate readers notifying me of any case(s) they have read where the court said that it determined th...
Tuesday, December 30, 2025

Statutory Interpretation as a Continuum and Equipoise in the Continuum (12/20/25)

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Continuing on my exploration of AI (I am still a novice), I asked several AI tools about ambiguity and continuum of confidence in statutory ...
Monday, December 29, 2025

Conservation Easement Case Set for Trial Only on Valuation (and No Other Issue) with No Post-Trial Briefs (12/29/25)

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I note that today, among the orders released, the following Order was issued setting a trial of the valuation issue (and no other issue) in...
Friday, December 26, 2025

Brockman Civil Case with Civil Fraud Penalties Settled (12/26/25)

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  I have written before on the Brockman multi-year tax evasion scheme. See   here . Brockman was indicted but, before he could be tried, he ...
Tuesday, December 23, 2025

IRS Seeks Comments on Proposed Revisions to Voluntary Disclosure Procedure (12/23/25)

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  On December 22, 2025, the IRS opened a 90-day public comment period, ending   March 22, 2026 , for proposed updates to its Voluntary Discl...
Friday, November 14, 2025

Tax Court on Default Rules in Statutory Interpretation-Herein Also of Chevron, Loper Bright and APA § 706(2(A) (11/14/25)

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In Apache Corp. v. Commissioner , 165 T.C. ___ No. 11 (11/1325), reviewed opinion, the Court addressed the momentous (to some) issue of whet...
Wednesday, November 12, 2025

Tax Court in Unanimous Reviewed Opinion Interprets and Applies the Accuracy-Related Economic Substance Penalty (11/12/25)

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In Patel v. Commissioner , 165 T.C. ___, No. 10 (11/12/25) (unanimous reviewed opinion), the Tax Court (Judge Jones) applied the interpreted...
Tuesday, November 4, 2025

Tax Court Yet Again Finds Bullshit Conservation Easement Grossly Overvalued (11/4/25; 11/16/25)

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In Paul Adams Quarrry Trust v. Commissioner , T.C. Memo. 2025-112, GS here and TN here , the Tax Court (Judge Toro) shot down another bulls...
Friday, October 31, 2025

Tax Court Warns Counsel in Advance of Trial in Syndicated Conservation Easement Case (10/31/25)

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In Cottonpatch Timber Company, LLC v. Commissioner (T.C. No. 26103-22, here , at #54 Order dtd 10/29/25), TN here , Judge Gustafson sent wa...