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Monday, April 28, 2025

Sixth Circuit Opines on Types of Deference after Loper Bright (4/28/25)

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In United States v. Bricker , ___ F.4th ___ (6th Cir. 2/22/25), CA6 here and GS here the majority held that 18 U.S.C. § 3582(c)(1)(A) allo...
Sunday, April 27, 2025

Conflicting Statutes of Limitations for Regular Tax Assessments and Restitution-Based Assessments (4/27/25)

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  In   United States v. Brown   (W.D. WA   Case No. 24-cv-05021   Dkt. No. 38 Order dated 4/21/25), GS   here   and CL   here , the Court up...
Monday, April 21, 2025

Court Dismisses Bivens Claim Against IRS Agents for Asserting Accuracy-Related Penalties (4/21/25)

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In Ray v. Priver , et al., 2025 U.S. Dist. LEXIS 71600, 2025 WL 1113406 (D. D.C. 4/15/25), CL here and GS here , The Court dismissed Ray’s ...
Friday, April 18, 2025

Political Thrashing Around Acting Commissioners and Commissioner of Internal Revenue (4/18/25; 4/19/25)

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I thought I was through posting for the day and even for a few days. But this new item popped up. Jonathan Swan, Andrew Duehren, Alan Rappep...

The Section 7217 Crime of Executive Office, including President, Requesting or Directing IRS to Examine or Audit (4/18/25)

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I have been thinking about President Trump’s public scrap with Harvard University, In doing so, I have reviewed § 7217, titled " Prohib...
Thursday, April 17, 2025

Another Bullshit Tax Shelter Goes Down; On Frank Lyon (4/17/25)

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Judge Lauber nails another bullshit tax shelter in GWA, LLC v. Commissioner , T.C. Memo. 2025-34, TC here at Dkt # 357, GS here [to come] a...
Monday, March 31, 2025

Tax Court Rejects Bullshit Syndicated Conservation Easement Shelter for the Usual Reasons (3/31/25)

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In Ranch Springs, LLC v. Commissioner , 164 T.C. ___, No. 6 (3/31/25), links below *, the Tax Court rejected another bullshit tax shelter, h...
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 **...